JUDGMENT K.N. Singh, J. - These are six writ petitions which raise common question of law. The petitioners were elected Pradhan of Gaon Sabha constituted under the U. P. Panchayat Raj Act, 1947. Election of each of the petitioners was challenged under Section 12-C of the U. P. Panchayat Raj Act. The contesting respondents who challenged the petitioners ,election paid a court fee of Rs. 1.50 on the application filed under Section 12-C of the Act. The Petitioners who were respondents to the election petition raised objection that the court fees paid was not sufficient. After hearing the parties the Sub-Divisional Officer dismissed this objection on the finding that the court fee paid was sufficient. Thereupon the petitioners approached this Court under Article 226 of the Constitution of India claiming relief for the issue of writ of certiorari quashing the orders of the Sub-Divisional Officers rejecting their objections and for the issue of direction directing the Sub-Divisional Officer not to proceed with the trial of the election petition unless proper court fee was paid by the respondents. 2. The Court Fees Act, 1870 is a central legislation which has been amended by the State legislature of Uttar Pradesh from time to time. The Act requires payment of court fee on applications, plaints, suits memorandum of appeals and documents which are filed and exhibited before any court or public officer at the rates laid down in the Act. Section 6 of the Court Fees Act, hereinafter referred to as the Act, lays down that no document of any kind specified as chargeable in the first or second schedule to & Act, shall be filed, exhibited or recorded in any court or shall be received or furnished by any public Officer unless in respect of such documents court fee is paid in an amount not less than that indicated by either of the said schedules. Schedule 1 to the Act, prescribes rates of tour. fee payable on documents which are chargeable on Advalorem basis. Schedule II prescribes fixed fees chargeable on documents which arc chargeable on Advalorem basis. Schedule II prescribes fixed fees chargeable on documents application, petitions filed before courts of law or public officers. Article 1 of schedule II relates to an application or petition. It prescribes a court fee of Rs. fee payable on documents which are chargeable on Advalorem basis. Schedule II prescribes fixed fees chargeable on documents which arc chargeable on Advalorem basis. Schedule II prescribes fixed fees chargeable on documents application, petitions filed before courts of law or public officers. Article 1 of schedule II relates to an application or petition. It prescribes a court fee of Rs. 1.50 n.p. on an application or petition filed before a District Magistrate or Collector or any officer subordinate to him under the village Panchayat Act. The respondents who filed the applications under Section 12-C of the U. P. Panchayat Raj Act questioning the election of petitioners as Pradhan of Gaon Sabhas paid a court fee of Rs. 1.50 n.p. on that application. Learned counsel for the petitioners urged that the court fee paid was insufficient, the amount payable was Rs. 200.00 as required by Article 22 of Schedule II of the Act. 3. Article 22 of Schedule II to the Act is in the following words: Number "22. Election petition questioning the election of any person. (a) As a President, Vice President or Adhyaksha, Upadhyaksha, Nagar Pramukh or Up Nagar Pramukh of a Municipal Board, Zila Parishad or Nagar Mahapalika or any other local body except those mentioned in clause (c). proper fee Two hundred rupees. (b) As a Sadasya or Vishishta Sadasya of a Nagar Mahapalika or as a member of a Municipal Board of Zila Parishad or any other local body except those mentioned in clause (d) (c) as a President or Chairman of a Notified or Town Area Committee. (d) as a member of a Notified or Town-Area Committee." One hundred and fifty rupees. Fifty rupees. Twenty five rupees. 4. The above entry in schedule II expressly lays down that a sum of Rs. 200.00 is required to be paid as court fee on an election petition questioning the election of any person as President, Vice-President or Adhyaksha, Upadhyaksha, Nagar Pramukh or Up Nagar Pramukh of a Municipal Boat d, Zila Parish had or Nagar Mahapalika or any other local body. Clause (b) of entry 22 prescribes Court fee of Rs. 150.00 payable on an election petition questioning the election of any person as a Sadasya or Vishishra Sadasya of a Nagar Mahapalika or as a member of a Municipal Board or Zila Parishad. Clause (b) of entry 22 prescribes Court fee of Rs. 150.00 payable on an election petition questioning the election of any person as a Sadasya or Vishishra Sadasya of a Nagar Mahapalika or as a member of a Municipal Board or Zila Parishad. Similarly clause (c) of Article 22 of Schedule II requires payment of court fee of Rs. 50.00 on an election petition questioning the election of a person as Chairman or President of a Notified or Town Area Committee. Clause (d) relates to an election petition questioning the election of a member of a Notified or Town Area Committee and a court fee of Rs. 25.00 is payable. None of the Clauses (a), (b), (c) and (d) of Article 22 of Schedule II expressly refer to an application questioning the election of a person as Pradhan of Goan Sabha or a member of Gaon Panchayat under the U. P. Panchayat Raj Act, 1947. There is thus no express provision in Schedule II prescribing court fee of Rs. 200/- on an application filed under Section 12-C of the U. P. Panchayat Raj Act, 1947 questioning the election of Pradhan. 5. Learned counsel for the petitioners urged that the words "or any other local body" occurring in clause (a) of Article 22 of Schedule II to the Act clearly indicate that a court fee of Rs. 200.00 is payable on an election petition questioning the election of a person as President of any other local body. It is further urged that similarly in clause (b) of Article 22 of schedule II of the Act, a court fee of Rs. 150.00 is payable on an election petition questioning the election of any person as a member of a local body. It was strenuously urged that Gaon Sabha was a "Local Body" and as such the court fee prescribed under Article 22 is chargeable on an election petition questioning the election of a Pradhan. As the election petitions in the present cases were insufficiently stamped, the same were not maintainable in law. 6. Article 22 of Schedule II to the Act expressly refers to an "election petition". It does not refer to an application. The election of a Pradhan of a Gaon Sabha is questioned by means of a an application under Section 12-C of the U. P. Panchayat Raj Act. 6. Article 22 of Schedule II to the Act expressly refers to an "election petition". It does not refer to an application. The election of a Pradhan of a Gaon Sabha is questioned by means of a an application under Section 12-C of the U. P. Panchayat Raj Act. The U. P. Panchayat Raj Act does not use the word "election petition," therefore the words used in Article 22 of the II schedule do not expressly cover an application filed under Section 12-C of the U. P. Panchayat Raj Act. Further clause (a) of Article 22 of Schedule II to the Act requires payment of court fee of Rs. 200.00 on the presentation of an election petition questioning the election of a person as President. Vice-President or Adhyaksha, Up adhyaksha, Nagar Pramukh or Up Nagar Pramukh of a Municipal Board, Zila Parishad or Nagar Mahapalika. It does not expressly mention the word "Pradhan of a Gaon Sabha". In the absence of these words clause (a) is not applicable to an election petition questioning the election of a person as Pradhan. It is true that in generic sense the term "local body" may include a Gaon Sabha also established under Section 3 of the U. P. Panchayat Raj Act, 1947, but a Gaon Sabha is a small body confined to a village or group of villages. The expression "local bodies" its genuine sense may include Municipal Boards, Nagar Manapalikas, Zila Parishads, Kshettra Samitis, Town Areas, Notified Areas and Goan Sabhas but a Goan Sabha cannot be equated with the Municipal Board, Nagar Mahapalika or Zila Parishad. There are significant dissimilatties in the two class of local bodies. The area, constitution, jurisdiction, power and duties and functions of a Gaon Sabha is quite different than that of other local bodies mentioned in Article 22. The legislature did not consider it necessary to prescribe heavy amount of court fee on the presentation of an application questioning the election of Pradhan of a Gaon Sabha which is admittedly a small unit, rather the primary unit in the set up of local administration. It is pertinent to note that the Act does not prescribe any court fee for an election petition challenging the election of Pramukh, Up Pramukh or member of a Kshetra Samiti consituted under the U. P. Kshettra Samitis and Zila Parishads Adhiniyam, 1961. It is pertinent to note that the Act does not prescribe any court fee for an election petition challenging the election of Pramukh, Up Pramukh or member of a Kshetra Samiti consituted under the U. P. Kshettra Samitis and Zila Parishads Adhiniyam, 1961. A Kshettra Samiti is an important unit in the local administration but the legislature did not mention Kshettra Samiti in Article 22, though Zila Parishad has been expressly mentioned in it. Kshettra Samitis and Zila Parishads both are constituted by one single statute enacted by the U. P. Legislature, but even then Aritcle 22 mentions only Zila Parishad and it does not mention Kshettra Samiti. The legislative intent is thus dear that the expression "any other local body" does not include a Gaon Sabha. This is further supported by the fact that though the court fees Act does not prescribe any fee on an election petition challenging the election of a Pramukh Rule 28(2) of the U. P. Kshettra Smitis (Election of Pramukhs, up Pramukhs and Settlement of Election Disputes) Rules 1962 framed under the U. P. Kshettra Samitis and Zila Parishads Adhiniyam requires payment of Rs. 75.00 as court fee. It appears that the provisions of the Court Fees Act were not considered sufficient to levy court fee on an election petition challenging the election of a Pramukh, therefore the aforesaid Rule was framed, even though it is difficult to deny that a Kshettra Samiti is an important local body. In the instant case neither Schedule II nor the Act nor the U. P. Panchayat Raj Act and Rules framed there-under expressly authorise levy of court fee on an application filed under Section 12-C of the U. P. Panchayat Raj Act questioning the election of a person as Pradhan of Gaon Sabha. In these circumstances it is difficult to accept the petitioner's contention, based on analogy and gensis of the expression "local body" occurring in clause (a) of Article 22 of Schedule II to the Act. 7. The provisions of Court Fees Act are fiscal in nature as it requires payment of court fee from litigant public. Its provisions must be interpreted strictly, any demand of court fee which is not covered by any of the express provisions of the Act and the Schedule cannot be up-held on the basis of any analogy. Principles of interpretation of fiscal statutes are well settled. Its provisions must be interpreted strictly, any demand of court fee which is not covered by any of the express provisions of the Act and the Schedule cannot be up-held on the basis of any analogy. Principles of interpretation of fiscal statutes are well settled. In interpreting fiscal statutes what one has to look to, is not the spirit of the statute but the letter of the law, if an item is not covered within the letter of the law, the subject cannot be made liable for the same. In Bank of Chettinad Ltd. v. Commissioner of Income Tax, Madras, A.I.R. 1940 P.C. 183 the Privy Council protested against the suggestion that in revenue cases the substance of the matter "may be regarded as distinguished from the strict legal position. The Privy Council affirmed the observations of Lord Russell of Killowen made in Inland Revenue Commissions v. Duke of Westminster, A.I.R. 1936 P.C. 1 Lord Russell observed thus "I confess that I view with disfavour the doctrine that in taxation cases the subject is to be taxed if in accordance with a Court's view of what it considers the substance of the transaction, the court thinks that the case falls within the contemplation or spirit of the statute. The subject is not taxable by inference or by analogy, but only by the plain words of a statute applicable to the facts and circumstances of his case." In making the above observations Lord Russell quoted with approval the observations of Lord Cairns made in the case of Partington v. Attorney General, (1869) 4 H.L. 100. which were in the following Words : "As I understand that the principle of all fiscal legislation it is this : if the person sought to be taxed comes within the letter of the law he must be taxed, however, great the hardship may appear to the judicial mind to be. On the other hand if the Crown seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of the law the case might otherwise appear to be." The above principles for interpreting fiscal statutes were quoted with approval by the Supreme Court in A. V. Fernades v. State of Kerala, A.I.R. 1957 S.C. 657. Bhagwati, J. speaking for the court laid down the law in the following words :- "It is no doubt true that in construing fiscal statutes and in determining the liability of a subject to tax one must have regard to the strict letter of the law and not merely to the spitit of the statute or the substance of the law. If the Revenue satisfies the Court as the case falls strictly within the provisions of the law, the subject can be taxed. If on other hand, the case is not covered within the four corners of the provisions of the taxing statute, no tax can be imposed by inference or by a analogy or by trying to probe into the intentions of the legislature and by considering what was the substance of the matter." The above principles laid down by the Supreme Court will apply with equal force in interpreting the provisions of the Court Fees Act. 8. In the instant case, neither the provisions of the Act nor Article 22 of Schedule II, expressly require payment of court fee of Rs. 200.00 on an application filed under Section 12-C of the U. P. Panchayat Raj Act questioning the election of a person as Pradhan of the Gaon Sabha Article 22, was amended by U. P. Act No. 14 of 1963. If the legislature intended to levy court fee of Rs. 200.00 on an election petition questioning the election of a Pradhan of Gaon Sabha, as applicable to the election petition filed against the President, Adhyaksha, Nagar Pramukh or Up Nagar Pramukh of a Municipal Board, Zila Parishad or Nagar Mahapalika, it would have made express provisions to that effect. In the absence of any express provision to that effect Article 22 does not apply. The argument that words "any other local body" contained in clause (a) of Article 22 are wide enough to include an election petition questioning the election of any person as Pradhan of Gaon Sabha is untenable. The State legislature of U. P. was conscious that there were local bodies constituted under various enactments in the State, such as, Nagar Mahapalikas, Municipal Boards, Zila Parishads, Kshettra Samitis, Town Area Committees, Notified Area and Gaon Sabhas and yet did not consider it necessary to make any express provision levying court fee of Rs. The State legislature of U. P. was conscious that there were local bodies constituted under various enactments in the State, such as, Nagar Mahapalikas, Municipal Boards, Zila Parishads, Kshettra Samitis, Town Area Committees, Notified Area and Gaon Sabhas and yet did not consider it necessary to make any express provision levying court fee of Rs. 200.00 on an election petition questioning the election of a person as Pradhan of the Gaon Sabha. The petitioners argument that Goan Sabha being a local body the question of election of Pradhan was covered by Article 22 is based on the principle or analogy, substance of the matter, and spirit of law. That argument cannot be up-held in view of the law laid down by the Supreme Court. 9. In any event even if the petitioners argument is accepted that the legislature intended to levy court fee on an application questioning the election of a person as Pradhan of the Gaon Sabha, it cannot be denied that the legislature failed to express its intention clearly. Article 22 to that extent is deficient. If there is any deficiency in Article 22 of Schedule II, the benefit cannot be given to the State for demanding court fee in such a situation. In C.A. Abraham v. Income Tax Officer, A.I.R. 1961 S.C. 609 the Supreme Court laid down the law in the following words : The interpreting a fiscal statute, the court cannot proceed to make good deficiencies if thereby any, the Court must interpret the statute as it stands and in case of doubt, in a manner favourable to the tax payer." The law laid down by the Supreme Court applies with full force in interpreting Article 22 of schedule II to the Act. In the absence of any express provision under Article 22 relating to payment of court fee on an application questioning the election of a person as Pradhan, it is doubtful that the court fee prescribed therein is chargeable on an application under Section 12-C of the U. P. Panchayat Raj Act. In that situation the benefit of doubt must be given to the subject against, the State. There is therefore no substance in the petitioners' contention. 10. There is another aspect of the matter which requires consideration. The payment of proper court fee on a document or an application is a matter between the citizen and the State. In that situation the benefit of doubt must be given to the subject against, the State. There is therefore no substance in the petitioners' contention. 10. There is another aspect of the matter which requires consideration. The payment of proper court fee on a document or an application is a matter between the citizen and the State. The defendants or the respondents to the proceedings which may have been initiated on an insufficiently stamped application have no right to move superior courts by appeal or revision or by filing writ petition under Article 226 of the Constitution. In that situation state may be the aggrieved party and not the defendant or the respondent. Deficiency in court fee on the application filed under Section 12-C of the U. P. Panchayat Raj Act does not affect petitioner's right they are not entitled to any amount which may be paid as court fee. It is the state which is affected and not the parties who may be contesting the proceedings. The petitioners therefore have no right to maintain the present petitions on the ground that the proper court fee was not paid by the respondent election petitioners. In Sri Rathnavarmaraja v. Smt. Vimla, A.I.R. 1961, S.C. 1299 the Supreme Court deprecated the tendency of defendant in a suit to approach High Court in revision against an order determining the Court fee payable. The Supreme Court held that payment of proper court fee was primarily a question between the plaintiff and the State. The defendant had no right to move superior courts by appeal or revision against the order adjudging payment of court fee payable on the plaint. The observations made by the Supreme Court apply with full force to the present case. The State has not questioned the deficiency in the court fee in the present cases. The petitioners have therefore no right to invoke the jurisdiction of this Court under Article 226 of the Constitution against the order of the Sub-Divisional Officer adjudging payment of court fee on the application under Section 12-C of the U. P. Panchayat Raj Act. The present petitions are therefore not maintainable. 11. In the result the petitions fail and are accordingly dismissed with costs.