Judgment :- 1. The petitioner-Company was assessed to sales-tax under S.35 of the Bombay Sales Tax Act, 1959, for the year 1972-73 by Ext. P4 dated 13-3-1975. A penalty was imposed upon it under Ext. P5 dated 13 81975. A notice of demand was served on it by the 3rd respondent, Deputy Tahsildar, Mattancherry, Cochin, under S.7 of the Kerala Revenue Recovery Act. These orders are challenged by the petitioner. 2. Counsel for the petitioner, Shri Chakkappan Kalliath, submits that Ext. P4 levying sales-tax in respect of the sales in question is null and void as such levy is barred under Art.286 of the Constitution. Consequently Ext. P5 imposing penalty upon the petitioner is also null and void. Counsel further submits that the notice issued under S.7 by the 3rd respondent Deputy Tahsildar is invalid as he is not a competent officer to initiate proceedings for collection of revenue due and payable to the Collector of Bombay. Counsel also submits that the provisions of either the Kerala Revenue Recovery Act, 1968, or the Revenue Recovery Act, 1890, do not authorise collection of revenue in one State on behalf of the authorities of another State. 3. The contention that Exts P4 and P5 are null and void for the reason that the imposition of tax is barred under Art.286 of the Constitution is based on the assumption that the sales in question took place in the course of import. No such contention is stated by the petitioner to have been urged before the authorities in Bombay. Whether or not the sales were effected in the course of import is essentially a question of fact which has to be determined by the competent authorities. Even assuming that this question had been urged by the petitioner and wrongly determined by the Sales-tax Officer in Bombay, Ext. P4 assessment was not challenged before the statutory authorities in Bombay. In the circumstances the petitioner cannot be heard to contend that Ext. P4 is a void order and therefore it is open to it to resist recovery on the strength of such order. Assuming that Ext. P4 is void, the petitioner ought to have promptly approached the competent court and had that order declared void by due process of law. 4. P4 is a void order and therefore it is open to it to resist recovery on the strength of such order. Assuming that Ext. P4 is void, the petitioner ought to have promptly approached the competent court and had that order declared void by due process of law. 4. An order, although void in law, remains for many purposes effective and operative until it is challenged and its invalidity is declared by a competent body or court. It is not open to a person to ignore an order made against him by a competent authority in the purported exercise of its statutory power solely on the ground that the order is null and void and resist all consequences flowing from it. It is not correct to say that an order which is void, is void in the sense that it has no effect at all. An order may be void ab initio, but it remains in effect and continues to operate until its invalidity is declared by the Court. Upon such declaration, the order goes out of existence as from the date on which it was made. But until then a void order is only voidable and it continues to operate against the person against whom it was made, and he is bound by the consequences flowing from the order. (See the principles stated by Lord Morris of Borth-y-Gest in Ridge v. Baldwin (1963) 2 WLR. 935 at 992-993; Lord Wilberforce in Calvin v Carr 1979 (2) All. E. R.440 at 445.) An order which is ultra vires, i.e., an order which is unauthorised by law and therefore outside jurisdiction, is null and void; whereas an order which is intra vires, i e., within jurisdiction, but vitiated by an error on the face of the record, is only voidable. [Anisminic Ltd. v. Foreign Compensation Commission (1969) 2 A. C. 147]. A void order, when quashed, is deprived of all legal effect right from its inception, whereas a voidable order remains valid even when it is quashed for the period of its operation. [See H.W R. Wade, Administrative Law, 4th Ed. P. 297]. [Anisminic Ltd. v. Foreign Compensation Commission (1969) 2 A. C. 147]. A void order, when quashed, is deprived of all legal effect right from its inception, whereas a voidable order remains valid even when it is quashed for the period of its operation. [See H.W R. Wade, Administrative Law, 4th Ed. P. 297]. But the distinction between 'jurisdictional errors' (using that expression in the sense in which it was understood by the House of Lords in Anisminic) and errors within jurisdiction, which is the criterion for distinguishing a void order from a voidable order, is so fine that it has reached almost the "vanishing point" (per K. K. Mathew J. in M. L. Sethi v. R. P. Kapur (AIR. 1972 SC. 2379 at 2385) ) or it is rapidly being eroded (per Lor Denning, Pearl-man v. Keepers & Governors of Harrow School [1978) 3 WLR. 736, 743). 'Void' and 'voidable' are concepts developed in the private law of contract and they are "ill adapted to the field of public law" (Lord Diplock in Hoffmann-La Roche & Co. A.G. v. Secretary of State for Trade and Industry (1975) A.C. 295,366; See also Lord Morris of Borth-y-Gest in Ridge v. Baldwin (1963) 2 WLR. 935 at 992-993; Lord Upjohn in Durayappah v. Fernando [1967] 2 A.C. 337 at at 353.] An order purportedly made in the exercise of a statutory power, whether void or voidable, is presumed to be valid until rebutted "by a party to legal proceedings in a court of competent jurisdiction who has locus standi to challenge the validity" of the order in question. [Lord Diplock, ibid, at p. 366]. As aptly put by H. W. R. Wade, ibid, at p. 300 "The reality of the matter, therefore, is that the court will invalidate an order only if the right remedy is sought by the right person in the right proceedings and circumstances. The order may be hypothetically a nullity, but the court may refuse to quash it because of the plaintiff's lack of standing, because he does not deserve a discretionary remedy, because he has waived his rights, or for some other legal reason. The order may be hypothetically a nullity, but the court may refuse to quash it because of the plaintiff's lack of standing, because he does not deserve a discretionary remedy, because he has waived his rights, or for some other legal reason. In any such case the 'void' order remains effective and is, in truth, valid." Extst P4 and P5, even if invalid, are effective and operative against the petitioner insofar as it did not seek the right remedy at the right time in the right proceedings in the right forum. 5. As regards the contention that the Deputy Tahsildar (3rd respondent) is not competent to issue Ext. P7 for the reason that the Collector (2nd respondent) who is the competent authority under S.69 of the Kerala Revenue Recovery Act is not entitled to delegate his power, it has only to be stated to be rejected in the light of the decision of this Court in Tahsildar, Alwaye v, Antony (1977 KLT. 26), over-ruling an earlier decision to the contrary in Antony v. Tahsildar, Alwaye (1975 KLT. 440). 6. I now come to the last contention, viz., the authorities under the Kerala Revenue Recovery Act are not competent to collect revenue at the behest of the authorities in Bombay. This contention is based on the fact that the Revenue Recovery Act, 1890, in S.3 does not specifically say that the Collector of a district is competent to send a certificate to the Collector of another district of any other State. All that S.3 says is that the Collector of a district may send a certificate to the Collector of another district and the latter is bound to proceed to recover the amount in accordance with such certificate. S.5 also speaks of the Collector of a district recovering amounts due under a certificate issued by the Collector of another district. S.10 refers to the duties of the Collectors to remit money collected on the basis of such certificates. It says: "Where a Collector receives a certificate under this Act from a Collector of another State ...he shall remit any sum recovered by him by virtue of that certificate to that Collector after deducting his expenses in connection with that matter." Ss. It says: "Where a Collector receives a certificate under this Act from a Collector of another State ...he shall remit any sum recovered by him by virtue of that certificate to that Collector after deducting his expenses in connection with that matter." Ss. 3,5 and 10 when read together clearly show that a Collector of a district in one State is empowered to collect the amount due to the Collector of a district of another State in accordance with the certificate issued by the latter. The Revenue Recovery Act, 1890, being a Central Act, applies to the country as a whole, and the Collector of a district means a Collector of a district anywhere in the country. A certificate issued by a Collector of a district is enforceable in another State, as in the case of a certificate issued by the Collector of another district in the same State. This is the view held by the High Court of Karnataka in Burman v. Comml. Tax Officer (28 STC. 637) which, with respect, I fully endorse. 7. For the reasons stated by me I see no merits in the various contentions raised by the petitioner. Counsel for the petitioner however submits that S.4 of Act I of 1890 enables the petitioner to institute a suit for repayment of the amounts paid by it in certain cases and that in the instant case the petitioner should not be denied such right. The petitioner, no doubt, has such rights as are available to it under S.4 and on that point there is no dispute. 8. The Original Petition is accordingly dismissed. No costs. Dismissed.