JUDGMENT : This application arises out of a proceeding under the provisions of the Orissa Public Demands Recovery Act which was started long back in the year 1963-64 against the father of the petitioner for recovery of certain demands under the Agricultural Income Tax Act. On the death of the certificate-debtor, all his heirs and legal representatives including the present petitioner were substituted in his place. At that stage, the hearing as contemplated u/s 9 of the Act. i.e., hearing and determining the objections filed u/s 8 of the Act denying the liability or the like, had been over and the proceeding was at the stage of sale of the properties of the certificate-debtor. The petitioner has annexed the sale proclamation dated April 27, 1981 (annexure - 1), which obviously establishes the stage at which the petitioner had been added in the proceeding. He, however, came to this court, without filing any objection in the certificate court, with a prayer that the certificate proceeding could not go on without providing an opportunity to him for filing fresh objections as provided u/s 10 of the Act. On that application, notice of admission and hearing was issued. Section 10 of the Act empowers the Certificate Officer, of course subject to the law of limitation, to amend the certificate by addition, omission or substitution of the name of any certificate-holder or certificate-debtor or by alteration of the amount claimed therein, as the case may be. The proviso to section 10 reads as follows : "Provided that when any such amendment is made, a fresh notice and copy shall be issued as provided in section 6." This is the sheet anchor of the petitioners case. On the basis of this provision, it was submitted that notwithstanding the stage of the certificate proceeding, the Certificate Officer was bound to give fresh notice to the petitioner enabling him to have a chance to deny the liability, etc. The submission is entirely misconceived as the heirs of the certificate-debtor were substituted when the properties were already advertised for sale, after the stage for filing the objections and determination of the objections was long since over. Therefore, they cannot be allowed to reagitate the objections regarding the liability of the certificate-debtor and the executability of the certificate. Such an interpretation, in our view, would be contrary to the scheme of the Act and would reopen many controversies. Therefore, they cannot be allowed to reagitate the objections regarding the liability of the certificate-debtor and the executability of the certificate. Such an interpretation, in our view, would be contrary to the scheme of the Act and would reopen many controversies. It may well be that if the Certificate Officer, after the substitution of the legal heirs, proceeds against some properties which were not originally contemplated and with respect to which the substituted heirs might have a positive claim against the liability of the properties for being proceeded against in the certificate case, then they can take recourse to the provisions u/s 20 of the Act making a claim or objection to the attachment or sale of the property in execution of the certificate in question on the ground that it is not liable as such. The writ application, therefore, being entirely misconceived, is dismissed. In the circumstances, we make no order as to costs.