JUDGMENT 1. THESE Rules are directed against orders of the tribunal below, affirming the petitioner's liability for the disputed Certificate claims for interest and costs under section 16a of the West Bengal public Demands Recovery Act. 2. IN all these cases, the facts are similar. The original proceedings were for assessment of sales-tax and, upon such assessment, Certificates were issued for recovery of the same. Thereafter, it appears, the petitioners, in the respective cases, made payments of the original demand under the Certificate and claimed satisfaction of the same. The Certificate Officer accepted these payments as having been made to satisfy the original demands and immediately directed calculation of interest and costs under section 16a of the above Act. Thereafter, steps were taken for recovery of the petitioner's dues under those heads, namely, interest and costs. 3. THE petitioners objected on the ground inter alia that amicable payments having been made and received of the original demands, no liability could be imposed on the petitioners for interest and costs under section 16a of the West Bengal Public Demands Recovery Act. 4. THE petitioners' objections were overruled by the tribunals below and, against these decisions, the present rules were obtained by the petitioners. The main contention before the tribunals below and also in this Court was that, in case of amicable payments of the demands under the original Certificates, section 16a would not apply to impose liability for interest and costs on the certificate-debtors. Whatever might have been the position prior to the exposition of the law by the supreme Court in (1) Messrs. R.B.H.M. Jute Mills, Katihar and others v. Certificate Officer, Katihar and others, air 1967 SC 400 under the analogous and corresponding provision (section 17) of the Bihar Public Demands Recovery act, the matter, must be deemed to be concluded against the petitioners by the above pronouncement of the Supreme Court, followed under the Bengal Act (section 16a) by this court in (2) Khardah Co. Ltd. v. State of West Bengal and others, 72 CWN 683. The petitioners' above contention must, accordingly, be overruled. 5. A point was sought to be made that the payments in question, when they were made, were made under protest and without prejudice to the petitioners' legal rights under the law. 6. IT is true that in the applications, which were made for purposes of those payments, such statements were incorporated. The petitioners' above contention must, accordingly, be overruled. 5. A point was sought to be made that the payments in question, when they were made, were made under protest and without prejudice to the petitioners' legal rights under the law. 6. IT is true that in the applications, which were made for purposes of those payments, such statements were incorporated. But, thereafter, claims were made for full satisfaction of the demands on the basis of those payments. It further appears that, before none of the tribunals below, was this point of payment having been made under protest and without prejudice to the petitioners' legal rights under the law, ever pressed and in the petitions of the present Rules too, that aspect or that averment is entirely wanting. In the circumstances, it must be taken that the said position was given up by the petitioners, who were content to rely upon those payments as amicable payments in full satisfaction of the dues under the original Certificates. A further point was made that the above payments were made at a time when the petitioners' objections were pending and there was no execution proceeding. 7. HAVING regard however to the above attitude of the petitioners, it cannot be held that the said objections were being insisted on or continued by the petitioners and, in one of these cases, there is an express order, rejecting or dismissing the said objection. In our view, on the records as they stand, the petitioners' objection under section 9 of the Public Demands Recovery act to the original Certificates must, in all the cases before us, be held to have been rejected or dismissed either expressly or by necessary implication. 8. FOR application again, of section 16a, no execution of the Certificate is necessary. It will be enough if the Certificate has been signed and filed. That will be the starting point of the running of interest and of the liability for costs. It is true that these have to be recovered in execution of the Certificate. But, on such execution, does not depend the liability itself. The liability is imposed prior to such execution. That will be the starting point of the running of interest and of the liability for costs. It is true that these have to be recovered in execution of the Certificate. But, on such execution, does not depend the liability itself. The liability is imposed prior to such execution. A further point was made in some of the cases that there was, for a particular portion of the relevant period for calculation of interest, stay of proceedings by the Certificate Officer at the instance of the Certificate-holder, for which no relief has been given to the petitioners concerned by the tribunals below. It appears, however, that that stay also was ordered by the Certificate officer in view of a stay of further proceedings, obtained by the petitioners before the higher authorities. In the circumstances, that order of stay by the Certificate Officer cannot be dissociated or disconnected from the order for stay made by the said higher authority at the instance of the petitioners. For a stay, obtained by a party at his instance, the party is entitled to no relief in the matter of interest. On this ground, the prayer in this behalf would also fail. 9. IN the above view, all the contentions, urged in support of these rules, fail and the Rules are discharged. 10. THERE will be no order for costs in any of them in the circumstances of these cases.