JUDGMENT Gulati, J. - This petition under Article 226 of the Constitution has been filed by Sri Hari Lal Arya, resident of Pipraich on behalf of himself and on behalf of Vyapar Mandal, Pipraich of which he is the Secretary. The Petitioners have challenged the imposition of octroi tax by the Town Area Committee of Pipraich. The only ground of attack is that the procedure prescribed for the levy of tax, such as its publication etc., has not been properly complied with. 2. Section 15-A of the Town Areas Act deals with the preliminary proposals for a tax sought to be imposed by the Town Area Committee and provides that subject to any rules made in this behalf by the State Government, the committee established for any town area shall, by resolution, frame proposals specifying :- (a) the nature of tax which it desires to impose, and (b) the amount or rate of tax and the persons or class of persons who are liable to pay the same. Sub-sec. (2) of this section requires the committee to prepare a draft of the rules which it desires the State Government to make in respect of the matter referred to in Section 39. Sub-sec. (3) then provides that the committee shall publish in the manner prescribed the proposals framed in sub-sec. (1) and the draft rules framed under sub-sec. (2). Under sub-sec. (4) any inhabitant of the Town Area may file objections and the committee shall take into consideration such objections before finally setting the proposals: Under sub-sec. (5) the proposals so settled along with the draft rules are to be submitted to the prescribed authority. 3. Section 15-B then deals with the imposition of tax and lays down that the Prescribed Authority may either reject the proposals or sanction them with or without modification and if the proposals are sanctioned, it shall forward a copy of the draft rules on the subject to the State Government under sub-sec. (3) of that section and after the rules have been framed by the State Government, a copy thereof shall be forwarded to the Prescribed Authority and then the committee shall, by a resolution, direct the imposition of the tax with effect from a date to be specified and forward a copy of the resolution to the Prescribed Authority, who shall notify the same in the manner prescribed. Sub-sec. Sub-sec. (4) of this section then provides that the notification under sub-sec. (3) shall be conclusive proof that the tax has been imposed in accordance with the provisions of this Act. 4. In exercise of the power under Section 15-A (3) of the Town Areas Act, the State Government has issued notification No. 680-TIIX-79-T-50 dated July 20, 1950, which reads as under : "In continuation of notification No. 652-TIIX-79-50, dated July 6, 1950, it is hereby notified that the "Governor, in exercise of the powers conferred by sub-sec. (3) of Section 15-A of the United Provinces Town Areas Act, 1914 (II of 1914), as amended from time to time, has made the following rule regarding the manner of publication of taxation proposals of town area committee after the previous publication as required by Section 39 (3) of the said Act : Proposals for the imposition of a tax framed under sub-sec. (1) of Section 15-A and the draft rules framed under sub-sec. (2) of Section 15-A shall be published : (a) by affixing copies thereof at the office of the committee and at such other conspicuous places as the committee may by resolution decide; and (b) in a local news paper (if any)." From a perusal of the foregoing provisions, it is obvious that the publication is required at two stages. At first the proposals and the draft rules are to be published by the Town Area Committee. Thereafter the final resolution of the committee directing the imposition of the tax has to be published by the Prescribed Authority. 5. It has been asserted in the counter-affidavit filed on behalf of the Town Area Committee that the committee passed a resolution on September 6, 1965 proposing the imposition of octroi and on September 10, 1965, the Chairman of the Committee forwarded a copy of the resolution along with the schedule of the proposed rates as also the bye-laws to the Trade organisations of the town named in the letter of September 10, 1965. Petitioner No. 1 is one of the persons to whom that letter along with its enclosures was sent in his capacity as the Chairman of the Sahkari Ganna Vikas Samiti, Pipraich. Petitioner No. 1 is one of the persons to whom that letter along with its enclosures was sent in his capacity as the Chairman of the Sahkari Ganna Vikas Samiti, Pipraich. It is further stated in the counter-affidavit that the resolution of September 6, 1965 was also announced by beat of drums in the town of Pipraich and the proposals along with the schedules and bye-laws were posted at all important public places of the town. It is also stated there is no local newspaper published from the town of Pipraich, but the proposals were published in the daily "AAJ" of September 24, 1965 which Paper has a wide circulation in the town of Pipraich. 6. We are of opinion that there was sufficient compliance as required by the notification referred to above and the grievance of the petition that there was no proper publication by the Town Area Committee is wholly unfounded. Moreover, the petitioner had been informed personally of the proposal to levy the tax by a letter served upon him and the petitioner filed objections also. If the letter sent to him did not contain full particulars of the tax, the petitioner could very easily have ascertained the further particulars from the office of the Town Area Committee. 7. In paragraph 15 of the counter-affidavit it has been stated that the Commissioner of Gorakhpur, who is the Prescribed Authority, invited objections by notification No. 3720121-164 (64-65) dated March 4, 1966 published in the U. P. Gazette dated March 19, 1966, but no objections were received against the proposals imposing the octroi in the town of Pipraich and as such the Commissioner confirmed the draft rules and the resolution imposing the octroi which was published in Notification No. 63.17112-164 (64-65) dated June 9, 1966 in the U. P. Gazette dated June 18, 1966. 8. Sri Shanti Bhushan, the learned Advocate General, appearing on behalf of the opposite parties, submitted that in the circumstances enumerated above, there was complete compliance of the Act and the rules requiring publication at different stages. He further submitted that even if there was some irregularity or lapse in this behalf, the imposition of tax could not be challenged in view of sub-sec. (4) of Section 15-B of the Act and sub-clause (5) of Section 23 of the U. P. General Clauses Act. He further submitted that even if there was some irregularity or lapse in this behalf, the imposition of tax could not be challenged in view of sub-sec. (4) of Section 15-B of the Act and sub-clause (5) of Section 23 of the U. P. General Clauses Act. He also drew our attention to the decision of the Supreme Court in the Municipal Board, Hapur v. Raghuvendra Kripal, A.I.R. 1966 S.C. 693. In that case water tax imposed by the Municipal Board of Hapur was challenged on the ground that the resolution of the Board framing the proposal to impose water tax was not published in a local newspaper of Hapur printed in Hindi and that the rule framed for the imposition of tax (lid not accompany the resolution which was affixed on the notice board at the office of the Board. In that case admittedly there was no proper publication inasmuch as the proposals were not published in a local news paper which admittedly was being published from Hapur. However, the Board relied upon Section 135 (3) of the U. P. Municipalities Act which provides that the notification of the imposition of tax under sub- scc. (2) shall be conclusive proof that the tax had been imposed in accordance with the provisions of the U. P. Municipalities Act. The Supreme Court accept- ed the contention of the Board and held that even though there was no strict compliance with the procedure prescribed for publication, yet in view of Section 135 (3), the legality or validity of the tax could not be questioned. 9. We are of opinion that the contention of the learned Advocate General must be upheld. In the first place the learned counsel for the petitioner has not been able to point out any substantial irregularity with regard to the publication and secondly even if there was any irregularity, the same cannot be a ground for challenging the imposition of tax, if it has been duly notified in the official gazette. 10. We find no force in this writ petition and the same is dismissed with costs.