Das, J.- By this common judgment we propose to dispose of both Civil Rule Nos. 225/75 and 226/75 as they contain similar facts and identical questions of law. 2. Mr. J. P. Bhattacharjee, learned Advocate General, Nagaland, who appears on behalf of the petitioners in both the Civil Rules, has raised the following preliminary points and contends that he shall not burden this Court to go into the merits of the case as, in his opinion, a decision on the preli­minary points will be enough for the purpose of this case. (a) Whether the Assam Board of Revenue while dis­posing of the revision petition under section 17 of the Assam Motor vehicles Taxation under section 5 of the Indian Limitation Act? (b) Whether the provisions of the Assam Motor Vehicles Taxation Act, 1936 and the Rules framed there­under do confer any power to condone the delay, if the revision application under section 17 of the aforesaid Act is made beyond the period as prescribed under sec­tion 17 of the Act? (c) Whether the Assam Board of Revenue can suo motu, without any specific prayer made by the aggrieved party for condonation of delay, condone the delay while considering the revision petition? -and- (d) Whether the Assam Board of Revenue cm enter­tain a petition under Section 17 of the Assam Motor Vehicles Taxation Act, 1936 preferred beyond the period of limitation? 3. Before we embark upon to consider the submission of the learned Counsel for the petitioners, it would be necessary to relate the facts of the case, in each Civil Rule. Civil Rule No. No. 225/75-Vehicle No. ASD 5448 bearing Engine No. JC-1077 and Chassis No. J 6 M 2-5-218631 was purchased by one Ram Suhasit Ojha under a hire-purchase agreement with M/s Hindusthan Motor Corporation Ltd. The hirer having failed to abide by the terms of the hire-purchase agreement, the Hindusthan Motor Corporation Ltd. for short "the Corporation" cancelled the hire-purchase agreement and took possession of the said vehicle on 26.3.71. Thereafter the Corporation informed the Motor Vehicles Department, Tezpur vide its letter No. 4/L22/116 dated 7.4.71 (Annexure-1 to the petition) that the vehicle was off-the-road and the same was lying in the garage of M/s Ashok Motors, Tezpur. The Corporation further informed that they could not submit the 'H' Form as the same could not be collected from the hirer. Thereafter the Corporation informed the Motor Vehicles Department, Tezpur vide its letter No. 4/L22/116 dated 7.4.71 (Annexure-1 to the petition) that the vehicle was off-the-road and the same was lying in the garage of M/s Ashok Motors, Tezpur. The Corporation further informed that they could not submit the 'H' Form as the same could not be collected from the hirer. On 3.5.72, the petitioner No. 1 purchased the said Engine and the Chassis from the Corporation as scrap mate­rials. The District Trasport Officer, Tezpur, Respondent No. 2. issued a demand Notice vide Memo No. DTO/3992/73 dated 7.11.73 (Annexure-II) to the petition calling upon it to pay the arrear dues of vehicle No. ASD 5448 amounting to Rs. 9,285/- from 1.4.70 to 31.12.73 within 31.12.73. On receipt of the said notice, the petitioner No. 1 preferred an appeal before the Deputy Commissioner, Tezpur under section 17 of the Assam Motor Vehicles Taxation Act, 1936, for short "the Taxation Act” which was numbered as Misc. Appeal No. 25 of 1973. After registration of the appeal, the learned Deputy Com­missioner called for the records of the case and also a report from the District Transport Office, Tezpur, Respondent No. 2. After hearing the appeal, the learned Deputy Commissioner by his order dated 4.2.74 allowed the appeal and set aside the order of the District Transport Officer, Tezpur. Thereafter, on 14.2.74, the District Transport Officer Tezpur, wrote a letter to the Commissioner of Transport, Assam intimating him about the result of the appeal and for taking further action in the matter. The Commissioner of Transport, Assam, Gauhati, Respondent No. 3 by the letter dated 5.3.74 (Annexure-IV to the petition) addressed to the Chairman, Assam Board of Revenue, Gauhati questioned the validity of the order passed by the Deputy Com­missioner, Tezpur in the aforesaid appeal stating, inter alia, that the cases involved substantial amount of revenue by way of motor vehicle tax and requested him to set aside the order of the learned Deputy Commissioner alleging that the remission of taxes given by the learned Deputy Commissioner was without sufficient ground and also mentioned that the matter had evoked Public resentment and the same might be taken up suo-moto. The learned Board of Revenue treated the aforesaid letter of the Commissioner of Transport, Assam, Respondent No. 3, as a revision petition under section 17 of the Taxation Act and the learned Board by its order dated 11.3.74 (Annexure-V to the writ petition) called for the record of the case and issued notice upon the petitioner No. 1. Accordingly the learned Board of Revenue registered a revision case being case No- 2MVTA/74. The petitioner No. 1 duly appeared before the learned Board on receipt of the notice dated 19.6.75 and filed an affidavit contending inter alia that the petitioner was not liable to pay the arrear taxes and dues of the vehicle No. 5448 inasmuch as the said vehicle was purchased on 3.5.72 in an unserviceable and most dilapidated condition and that the said vehicle was under repair since the date of purchase and was not placed on the road for plying during the period for which the tax had been assessed. It was further contended that the assessment made by the District Transport Officer was arbitrary and based on conjectures and surmises. The learned Board of Revenue heard the revision application on 12.11.74 and by its judgment and order dated on 7-1.75 set aside the order of the Deputy Com­missioner dated 4.2.74 and restored the order of the Respon­dent No. 2, District Transport Officer, Tezpur, dated 7.11.73. Civil Rule No. 226/75.-The facts of the case in Civil Rule No. 226/75 are similar to that of Civil Rule No. 225/75, as stated above, except that the petitioner No. 1 purchased the vehicle No. ASD 5565 with the Engine No. JC 1439 and Chassis No. JSM 2-5-HM-218760 from the Hindustan Motor Corporation as scrap on 3.5.Ij. and at the time of the said purchase, the engine was in an unserviceable condition and the petitioner got the same re-assembled and made it serviceable. On 23.10.73, the vehicle was put on road in order to test its road-worthi­ness, while it was on test on 23.10.73, the Enforcement Ins­pector seized the vehicle and took the vehicle to the office of the Respondent No 2, the District Transport Officer, Tezpur. On the very same date the petitioner No. 1 made a representation to the Deputy Commissioner, Tezpur for release of the vehicle and the learned Deputy Commissioner released the vehicle to the petitioner No. 1 on 25.10.73. On the very same date the petitioner No. 1 made a representation to the Deputy Commissioner, Tezpur for release of the vehicle and the learned Deputy Commissioner released the vehicle to the petitioner No. 1 on 25.10.73. On 2.11.73, the petitioner No. 1 applied for Form-E for registration of the vehicle after the vehicle in question became road-worthy. The District Trans­port Officer, on receipt of the said application, by his letter dated 7.11.73 bearing Memo No. DTO/3992/73 (Annexure-HI to the writ petition) issued a Demand Notice calling upon it to pay the arrear dues of the vehicle from 1.1.70 to 31.12.73 amounting to Rs, 9, 896/- within 31.12.73. The petitioner, there­after, preferred an appeal before the learned Deputy Commi­ssioner. Darrang at Tezpur under Section 17 of the Taxation Act against the aforesaid Demand Notice, who by his order dated 4.2.74 allowed the appeal by setting aside the order of the Respondent No. 2, District Transport Officer, holding that the demand of tax after 1.8.70 and prior to 30.9.73 was not valid. However, the petitioner was directed 10 pay the tax from the quarter commencing from 1.10.73 after which the ownership of the vehicle would be transferred formally in the name of the petitioner No. 1. On 14.2.74, as already stated in Civil Rule No. 225/75, the Respondent No. 2 addressed a fetter to the Respondent No. 3 intimating the latter the result of the appeal and requesting him to take further action in the matter, who, in turn, addressed a letter dated 5.3.74 (Annexure-V to the writ petition) to the Chairman, Assam Board of Revenue making a similar request as has already been stated while narrating the case of Civil Rule No. 225/75 and accordingly the Revision petition No. 1 MVTA/74 was registered by the learned Board of Revenue. The petitioner No. 1 appeared be­fore the learned Board of Revenue and filed affidavit. Both the revision petitions were heard together by the Board of Revenue and by its order dated 7.1.75 set aside the order of the learned Deputy Commissioner and restored the order passed by the Respondent No. 2, District Transport Officer. Both these orders have been impugned in this writ petitions by the petitioners. 4. Both the revision petitions were heard together by the Board of Revenue and by its order dated 7.1.75 set aside the order of the learned Deputy Commissioner and restored the order passed by the Respondent No. 2, District Transport Officer. Both these orders have been impugned in this writ petitions by the petitioners. 4. Before, we deal with the preliminary points urged be­fore us by the learned Counsel for the petitioners, we think it necessary to read the provision of section 17 of the Taxa­tion Act, which is to the following affect:- "17. Appeal-Any person aggrieved by an order rela­ting to the assessment, imposition of recovery of a tax may within a period of thirty days from the date of such order prefer an appeal to the Deputy Commissi­oner, or, if the Deputy Commissioner is the Officer who passed such order, then to the Commissioner. Every order in appeal passed by a Deputy Commissioner, or by a Commissioner under this section shall be final subject to the powers of revision by the Assam Board of Revenue constituted under section 3 of the Assam Board of Revenue Act, 1962 (Assam Act No. XXI of 1962).'' No doubt, the Assam Board of Revenue constituted under the provision of the Assam Board of Revenue Act, 1962 has been conferred with the power of revision against an appellate order passed either by the Deputy Commissioner or by the Commissioner relating to assessment and imposition of recovery of a Tax on a motor vehicle, but the period for presentation of such revision has been prescribed under sub-rule (2) of Rule 40 of the Assam Motor Vehicles Taxation Rules, 1936, which reads as under:- " 40. Appeals-(1) * * * (2) At any time within 21 days from the date of an appellate order excluding the time required for obtaining a copy of the order any aggrieved person may submit to the Revenue Tribunal in writing an application for revision of such order. Such application shall bear a court fee stamp of Rs. 1/8/0 and be accompanied by a certified copy of the appellate order. Such application shall bear a court fee stamp of Rs. 1/8/0 and be accompanied by a certified copy of the appellate order. The Revenue Tribunal may if it considers that there is no sufficient ground for interfer­ing, dismiss the application summarily, or call for the proceedings held by the appellate authority or make such enquiry from him as is thought necessary and pass such order as it thinks fit." from a bare perusal of the aforesaid two provisions, a time-limit has been prescribed for presentation of such revision application, but there is no provision in the Rule itself as to whether the period can be extended if the petition for revision is preferred beyond the period of limitation. 5. The learned Counsel for the petitioners before making his submissions relating to the first preliminary point as to whether the provision of Section 5 of the Limitation Act can be extended to cover up the provisions of Taxation Act and the Rules framed thereunder, has referred to us various other relevant provisions under the Taxation Act in order to draw an analogy in support of his contention that the provision of section 5 of the Limitation Act does not bring within its fold, "the Assam Motor Vehicles Taxation Act, 1936" and the Rules framed thereunder as to empower the Board to condone the delay in presenting a revision petition. In this connection, the learned Counsel has made reference to the provision of Sec­tion 31A of the Assam Finance (Sales Tax) Act, 1947 wherein specific power has been conferred on the Board to condone the delay under the aforesaid Section of law. Sub-section (10) of section 32 of the aforesaid Act specifically provides that section 5 of the Limitation Act has direct application in a case if reference is made beyond time under the Assam Finance (Sales Tax) Act, 1956. On the above context, the learned Counsel has submitted that the Board has the power to condone the dealy as it has been specifically empowered by virtue of section 31A(2) of the Sales Tax Act, 1947. The learned Counsel has next re­ferred to us the provisions of section 20A of the Assam Finance (Sales Tax) Act, 1956. On the above context, the learned Counsel has submitted that the Board has the power to condone the dealy as it has been specifically empowered by virtue of section 31A(2) of the Sales Tax Act, 1947. The learned Counsel has next re­ferred to us the provisions of section 20A of the Assam Finance (Sales Tax) Act, 1956. Sab-section (2) of Section 20A of the aforesaid Act empowers the Board to admit an appeal after expiry of the period of 60 days referred to in sub-section (I) of section 20A if it is satisfied that for the reasons beyond the control of the appellant or for any other sufficient cause, the appeal could not be filed within time. The learned Counsel has also referred to us the provision of section 19 of the Assam (Sales of Petroleum etc.) Taxition Act, 1955, wherein a specific power has been given to the Board for condonation of delay in case the petition is preferred beyond time. A similar provision exists under section 42 of the Assam Purchase Tax Act, 1967 for condonation of delay if the petition is preferred beyond time. The learned Counsel has also placed before us the provisions of section 26 of the Assam Agricultural Income Tax Act, 1939 and has contended that the Board has been conferred with the power to condone the delay under the aforesaid section of law. Our attention has been further drawn to the various provision of the Indian Income Tax Act, 1922 and the Income Tax Act, 1961 and has made particular reference to proviso to section 256 of the Indian Income Tax Act, 1961 which envisages specific power for condonation of delay. In course of his argument, the learned Counsel has placed before us a decision of this Court in D. P. Agarwalla vs. CIT Assam and ors. (Civil Rule No. 1 CM) of 1968 disposed of on 13.11.72). That was a case under section 66(3) of the Indian income Tax Act, 1922 for qua­shing an order passed by the learned Income Tax Appellate Tribunal dismissing a petition under section 66(1) of the afore­said Act as barred by limitation. (Civil Rule No. 1 CM) of 1968 disposed of on 13.11.72). That was a case under section 66(3) of the Indian income Tax Act, 1922 for qua­shing an order passed by the learned Income Tax Appellate Tribunal dismissing a petition under section 66(1) of the afore­said Act as barred by limitation. Pathak, J. (as he then was) speaking for the court held that the Income Tax Appellate Tribunal in disposing of an application under section 66(1) of the aforesaid Act is not a "Court" and therefore no applica­tion under section 5 of the Limitation Act, 1963 is maintainable before the Tribunal while disposing of an application under section 66(1) of Income Tex Act. The learned Counsel for the petitioner has sought assistance from the aforesaid decision of this Court and contends that, takingsa similar view of the case the Assam Board of Revenue while disposing of a revision application under Section 17 of the Taxation Act cannot condone the delay being not a "Court" either suo moto or on the application of the party for condonation of such delay in pre­senting a revision application. 6. The learned Deputy Commissioner passed the order in Misc. Appeal No. 25 of 1973 on 4.2.74. Thereupon, the District Transport Officer, Tezpur, Respondent No. 2, informed the Commissioner of Transport, Assam, Respondent No. 3 by a letter written on 14.2.74 who, in turn, addressed a letter on 5.3.74 to the Chairman, Assam Board of Revenue for a revision of the order and the action taken by the Commissioner of Transport is apparently beyond the period of 21 days as pres­cribed by the Rules. On a perusal of the order sheet of Misc. Case No. 24/73 maintained by the Deputy Commissioner, Darrang it appears that on 13.11.73 the Deputy Commissioner called for the records of the case and a report from the District Transport Officer, Tezpur on the ground that an appeal had been filed by the petitioner. By the same order the Deputy Commissioner stayed the realisation of the arrear dues till disposal of the appeal and fixed 30.11.73. On 30.11.73, the Deputy Commissioner was cut of station and the case records were put up before the Sub-Divisional Officer, Tezpur, who ordered to put up the case before the Deputy Commissioner on 17.12.73. By the same order the Deputy Commissioner stayed the realisation of the arrear dues till disposal of the appeal and fixed 30.11.73. On 30.11.73, the Deputy Commissioner was cut of station and the case records were put up before the Sub-Divisional Officer, Tezpur, who ordered to put up the case before the Deputy Commissioner on 17.12.73. Accordingly, the case was put up before the Deputy Commi­ssioner on 17.12.73, who rendered the following order:- "17.12.73 Appellant is present and files a written statement. Perused D.T.O.'s report dt. 29.11.73. Records as called for vide order dt. 13.11.73 has not jet been received from D.T.O. Ask D.T.O. to send the relevant records of the vehicle by 28.12.73. Fix 12.1.1974 for hearing. Sd/- 17/12/73 Deputy Commissioner" On 12-1.74, the Additional Deputy Commissioner passed the following order:- "12.1.74 D.C. is out on tour. Appellant it present. Records received from D.T.O. Put up to D.C. on .21.1.74 for hearing. Sd/- A.D.C. 12.1. The appeal was finally heard on 21.1.74. But from the Order Sheet of the Deputy Commissioner, it does not appear whether the District Transport Officer, Tezpur, Respondent No. 2 herein, was either personally present or represented through an Advocate. But it is apparently clear that on receipt of the notice of appeal, the District Transport, Officer, Tezpur, gave a parawise comment vide his letter No. DTD/4186/73 dated Tezpur the 29th November, 1973 stating, inter alia that the appeal was not within the purview of section 17 of the Taxa­tion Act and that the same would lie under section 35 of the Motor Vehicles Act as the case of the petitioner was against the order of refusal of registration and for Kusal of transfer of ownership of the vehicle. Therefore, it cannot be said that the District Transport Officer, Respondent No. 2, had no knowledge or information about the disposal of the appeal inasmuch as the respondent No. 2 contested the appeal on facts as well as on various legal grounds. We have also perused the letter dated 14.2.74 bearing No. DTD/47/74 written by the District Transport Officer to the .Commissioner of Transport, Assam at Gauhati wherein the District Transport Officer has stated that "the appellate orders of the Deputy Commissioner dated 4.2.74 received by the undersigned on 12.2.74 appear to be perfunctory leading to a loss of Govt. revenue to the extent of more than Rs. 19,000.00". revenue to the extent of more than Rs. 19,000.00". On receipt of the aforesaid letter, the Commissioner of Transport vide his office letter No. SST/MV/6/74/29 dated 5/3/74 (Annexure-IV to the writ petition) requested the Chairman, Assam Board of Revenue, Gauhati to invoke the jurisdiction of the Board suo moto and revise the order of the Deputy Commissioner. The said petition, though affixed with higher denomination of stamp as court fees than what has been prescribed by the Rules, does not appear to be accompanied by a certified copy of the appellate order as provided by Rule 40(2) of the Taxation Rules. On receipt of the application, the learned Board of Revenue passed an order on 11.3.74 referring the letter dated 5.3.74 and called for the record of the case and issued notices upon the petitioners who were arayed as opposite parties in the said revision application. It may be noted here that the District Transport Officer was made a party-respondent in the appeal preferred before the Deputy Commissioner and the appeal being contentious, he submitted parawise comments agai­nst the contentions of the appellant in that case, and as such it cannot be said that the District Transport Officer had no knowledge about the result of the appeal. As a party-respon­dent and more so being a responsible officer of the Motor Vehicles Department of a District, it was obligatory on the part of the District Transport Officer to enquire about the result of the appeal at the same was contested by him. It may be con­strued that it was a mere negligence on the part of the Dis­trict Transport Officer in not taking any action to know about the result of the appeal preferred by the petitioner herein till 12.4.74, but it does not cast a duty on the appellate autho­rity to send a certified copy of the order or a copy thereof unless there is a specific direction in the order itself. More, in this case, the revision petition suffers from two infirmities (i) it was not filed in accordance with sub-rule (2) of Rule 40 of the Taxation Rules-being not accompanied by a certified copy of the judgment; and (ii) the petition was filed beyond the period of 21 days as prescribed by law. More, in this case, the revision petition suffers from two infirmities (i) it was not filed in accordance with sub-rule (2) of Rule 40 of the Taxation Rules-being not accompanied by a certified copy of the judgment; and (ii) the petition was filed beyond the period of 21 days as prescribed by law. On a perusal of the record, we do not find any material, nor any applica­tion supported by an affidavit or even a verified petition stat­ing the reasons for not filing the revision application within time. The Order sheet maintained by the learned Board of Revenue also does not contain any such material. Under these circumstances we are not in a position to connect the date of knowledge from the date of the appellate order. In the present case, while the District Transport Officer submitted the records of the case and also filed comments rebutting the con­tentions of the appellant (the petitioner herein) before the appellate authority, it must be presumed that the District Transport Officer was well-aware of the result of the appeal; but negligently enough did not care to come within time for revision to invoke the revisional power of the learned Board of Revenue. On a perusal of the judgment and order of the learned Board of Revenue, we do not find any material as to how the learned Board of Revenue could condone the delay without recording any reason for condonation of such delay even if it is held that the Board has power to condone the delay. We, however, do not express any opinion whether the learned Board of Revenue is a "Court" or not for the purpose of condonation of delay under section 5 of the Limitation Act in view of the conclu­sion we have reached on the facts and circumstances of the case. Moreover, there was no application under section 5 of the Limitation Act for condonation of any delay. 7. Mr. D.N. Konwar, learned Government Advocate, Assam, has referred to us a few provisions of the Assam Board of Revenue Act, 1962 and the Assam Board of Revenue Regulation (Regulation 1 of 1963). The learned Government Advocate has referred to us section 4 of the Assam Board of Revenue Act, 1962, which lays down the power and jurisdiction of the Board to hear the matters as prescribed in Schedule-A of the aforesaid Act. The learned Government Advocate has referred to us section 4 of the Assam Board of Revenue Act, 1962, which lays down the power and jurisdiction of the Board to hear the matters as prescribed in Schedule-A of the aforesaid Act. Serial No. 4 of Schedule-A runs as follows: "4. The Assam Motor Vehicles Taxation Act, 1936 (IX of 1936). Revision of orders under section 17." No doubt, the Assam Board of Revenue has been empo­wered with revisional power under section 17 of the Taxation Act. But sub-section (3) of section 7 of the Assam Board of Revenue Act as referred to us is to the following effect:- "7(1) * * * (2) * * * (3). In computing the period of limitation, the provi­sion of the Indian Limitation Act, 1908 applicable to the applications for review of a judgment or order of a Civil Court shall, so far as may be, apply to applications for review under this section." On a bare perusal of the said provision what we find that the Board can review its own judgment and in case the appl­ication is made beyond 90 days as Prescribed by sub-section (2) of section 7 of the Act, the Board can extend the period of limitation by invoking the provision of sections of the Indian Limitation Act. This section deals with the Board's power of review of its own judgment. Therefore, the provision of section 7 as referred to us by the learned Government Advocate cannot help the respondent to extend the period of limitation in a case of revision under section 17 of the Taxation Act. Mr. Konwar further submits that the Board is the creature of the statute and has been empowered by the statute to decide the matter as prescribed therein under the frame works of its own regula­tion of conduct the business of the Board. However, the lear­ned Counsel has not been able to impress upon us by pointing out a definite provision as to whether the Board can extend the period of limitation in case of a revision application under section 17 of the Taxation Act if made beyond the period of limitation. However, the lear­ned Counsel has not been able to impress upon us by pointing out a definite provision as to whether the Board can extend the period of limitation in case of a revision application under section 17 of the Taxation Act if made beyond the period of limitation. The learned Government Advocate has also not been able to show us any material from record as to whether the petition for revision was in time in view of the fact that the information about the result of both the appeals was received by the District Transport Officer only on 12.4.74 and not earlier. The respondent also could not deny that they were never informed about the institution of the appeal or that they had no knowledge whatsoever about the result of the appeals. We have ourselves carefully gone through the records of the Courts below but we have not been able to lay cur hands on any such material wherefrom we can deduce that the revi­sion petition was not barred by limitation. The learned Govern­ment Advocate also could not convince us about the above proposition. We are therefore convinced that in absence of any specific power conferred on the Board by the statute, the Board cannot extend the period of limitation by condoning the delay to entertain a revision application made under section 17 of the Taxation Act. Accordingly, we hold that the learned Board committed an error in condoning the delay in the manner in which it has been done. It may be noted here that unlike the other provisions as referred to above in various Taxation Acts, the provision of section 17 of the Taxation Act has been regulated by one Rule 40 of the Taxation Rules wherein the period of limitation has been prescribed with no further power either to extend period by the Rule itself or by invoking the provision of Section 5 of the Limitation Act, 1963. In our view, the legislatures in their wisdom thought it best not to keep any provision for such condonation of delay on the basis of the object of the Act itself and the Rules framed thereunder. Accordingly we hold that the provi­sion of Section 5 of the Indian Limitation Act cannot be made applicable to condone the delay in making an revision applica­tion under Section 17 of the Taxation Act. Accordingly we hold that the provi­sion of Section 5 of the Indian Limitation Act cannot be made applicable to condone the delay in making an revision applica­tion under Section 17 of the Taxation Act. In the above view of the matter, we are of the opinion that the learned Board committed an error in entertaining the revision applications which were obviously barred by time. We may further add that it is a fundamental principle in constru­ing BB Act of Parliament to give to it ordinary and gramma­tical meaning if this produces no repugnancy or inconsistency. In some cases a limitation may be put on the constructions of the wide terms of a statute. Lord Haldane said in Watney Combe, Reid and Co. Ltd. v. Berners, 1915 AC 585 :- "The intention must be found in the language finally adopted in the statutes under consideration and in that language alone. No doubt, general words may, in cer­tain cases, properly be interpreted as having a meaning or scope other than the literal or usual meaning. They may be so interpreted where the scheme appearing from the language of the legislature read in its entirety, points to consistency as requiring the modification of what would be the meaning apart from any context, or aparat from the purpose of the legislature as appearing from the words which the legislature has used, or apart from the general law." In deciding what may be done under statutory powers, courts of law will always take into consideration the objects for which the statutory powers have been conferred. It can, however, be seen in some cases that statutory enactments although expressed in affirmative language are sometimes treated as having a implied, and that their provisions, through as Lord O'Hagan said in R. v. All Saints, Wigan 1 (1876) AC 611:- "Affirmative in words are not necessarily so if they are absolute, explicit and peremptory. If an affirmative statute directs a thing to be done in a certain way, that thing shall not, even if there be no negative words, be done in any other way." “What is done,'' said Lord Ellen Borough in Langton vs. Hughes, "any contravention of the provisions of an Act of parliament cannot be made the subject of an action''. (Vide Craies on Statute Law, 6th Edn. page 251). (Vide Craies on Statute Law, 6th Edn. page 251). It is well recognised rule that statute should be interpreted, if possible so as to respect vested rights, and such construction should never be adopted if the words are open to another construc­tion. This principle of construction is thus accurately stated by Sedwick (statutory Law, 2nd End. Page 287):- "The more correct version of the doctrine appears to be that statutes of these classes are to be fairly consi­dered and faithfully applied according to the intent of the legislature, without unwarrantable severity on the one hand or unjustifiable leniency on the other, in cases of doubts the courts inclining to mercy". There should not be any relaxation of rule of strict cons­tructions. The distinction between strict and liberal construc­tion has almost disappeared with regard to all classes of statutes whether penal or not, are now construed by substan­tially the same rule. All modern Acts are framed with regard to equitable as well as legal principles. They are construed now with reference to the true meaning and real intention of the legislature. In Stephens on v. Higginson, "The Rule was thus, stated by Lord Truro," in construing an Act of Parlia­ment every word must be understood according to the legal meaning, unless it shall appear from the context that the legislature has used it in a popular or more enlarged sense". (Vide Craies on Statute Law, 6th Edn. pages 531 and 532). The trouble maker is the time-limit. To decide whether the legislature really wanted to prohibit the presentation of the revision petition beyond the period of limitation as prescribed under Rule 40 (2) of the Rules, we have to bear in mind the object of the Act and the Rules framed thereunder, the inter­est of the litigant and the respective rights of the parties. What Rule 40(2) says that when a petition for revision is made beyond time, no opportunity visualised by that rule need be given to condone the delay. The underlying idea perhaps being that if the petition is time-barred, the same cannot be treated as a valid revision whatever prejudicial interest might have been caused to parties to the litigation. We cannot, however, stress the language of the provisions which would defeat the object behind it. The underlying idea perhaps being that if the petition is time-barred, the same cannot be treated as a valid revision whatever prejudicial interest might have been caused to parties to the litigation. We cannot, however, stress the language of the provisions which would defeat the object behind it. Rule 40(2) assured a person that 21 days is the time-limit and such assurance cannot be whittled down by so interpreting the provisions which would make the entire prov­ision nugatory. Before parting with the case, we wish to observe that the petitioners became the owners of the respective vehicles on and from the date of their purchase or in other words, on and from the date of their taking possession of the vehicles as per definition of the term "owner" under the Assam Motor Vehicles Taxation Act, 1936, which runs to the following effect.:- "(h), 'Owner' means, where the person in possession of a motor vehicle is a minor the guardian of such minor and in relation to a motor vehicle which is the subject of a hire purchase agreement, the person in possession of the vehicle under that agreement." We have already put forth the facts of the cases of both the Civil Rules and we do not think it necessary to repeat it over again- Since we have decided the cases on the prelimi­nary points urged before us by the learned Counsel for the petitioners, we do not feel it necessary to burden our judg­ment by entering into the merits of the case, as the learned Counsel for the petitioners in both the Civil Rules has sub­mitted at the very outset of commencing his arguments that a decision on the preliminary points by this Court, if held in favour of the petitioners in both the cases, would be enough for the purpose of this case. In the result, both the petitions are allowed. Both the impugned orders are quashed. Rules are made absolute. But in the facts and circumstances of the case, we make no order as to costs.