Judgment :- When recovery of tax was seriously attempted by the State, (more than twenty years back, after they had so become due), resistance was repeated by the defaulting petitioner. The provisions of the General Sales Tax Act, 1963, the Limitation Act, 1963 and the decision of this Court in AK. Nanu & Others v. State of Kerala and Others, 1987 (2) KLT 912, had been relied upon in that desperate attempt. 2. The sum demanded is on the basis of an assessment for sales tax. The demand notice was served on the assessee on 25-3-1966. The demand was not satisfied. 3. There is no indication of any exertion made by the assessing authority for realising the tax actually assessed. Once the assessment is over, the assessing authority is free from the botheration of recovery - would appear to be the attitude which had been taken by him. 4.The next step taken for realization of tax as is seen from the counter affidavit, is the requisition made on 30-11-1972 (more than six years later!) to the District Collector for initiation of recovery proceedings invoking the provisions of the Revenue Recovery Act. The requisition had its repose in some corner of the Collectorate till 17-7-1981. A certificate for recovery was issued at long last on 6-8-1981. A demand notice dated 25-8-1981, preceding attachment was served on the petitioner on 1-9-1981. That too did not evoke any response from the petitioner. The property of the petitioner admeasuring 1 acre 37 cents owned by the petitioner was attached under S.36 of the Revenue Recovery Act on 6-1-1982. The petitioner then filed his objections on 13-1-1982. 5. The objections were overruled by order dated 25-2-1982. The matter was taken up before the Board of Revenue which also rejected the contention by Ext.P2 dated 13-3-1984. The further approach to the Government was of no avail. The Government also repelled petitioner's contention in Ext.P5. The adverse orders have been challenged in this original petition. 6. As indicated earlier, the principal contention is that the recovery is barred by limitation and that consequently, the further steps in that behalf should be stopped. 7. It was agreed that under S.23(1) of the General Sales Tax Act, arrears of sales tax shall be collected as if it were an arrear of land revenue due. 6. As indicated earlier, the principal contention is that the recovery is barred by limitation and that consequently, the further steps in that behalf should be stopped. 7. It was agreed that under S.23(1) of the General Sales Tax Act, arrears of sales tax shall be collected as if it were an arrear of land revenue due. Non-payment of the tax demanded within the prescribed period automatically imposes on the property a statutory charge. According to counsel, a suit for enforcing a charge is specifically provided for under Art.62 of the Limitation Act. Only a comparatively short period of 12 years is available thereunder. The inaction of the Government officials, individually and collectively has exceeded even that period; recovery is, therefore tabooed under our system of law - is the specious contention advanced on the basis of the above facts. Supportive arguments were also advanced based on S.23(2) of the Act. 8. A dichotomy of recovery process is indicated under the Act: one by pressing into service the process of revenue recovery and the other, the methodology employed in the recovery of fine. In the case of recovery of fine, a time limit of six years is statutorily fastened. That time limit should, in substance, be imported into the entire recovery process and viewed that way, recovery would be impermissible after the expiry of six year period-so ran the arguments. The arguments, however, attractive at first blush, may not survive deeper scrutiny. 9. The learned Government Pleader projected Article 112 of the Limitation Act as a strong point to resist the contention of the petitioner. That article reads as follows: "Description of suit Period of Time from which period Limitation. begins to run. 112. Any suit (except a suit before the When the period of limitation Supreme Court in the exercise of its would begin to run under this original jurisdiction) by or on behalf of Thirty Act against a like suit by a pri- the Central Government or any State Years. vate person." Government, including the government of the State of Jammu and Kashmir. The period prescribed therein is a longer one, ie. 30 years. That period is not yet over. The only further question is whether that Article can be pressed into service by Government. 10. Counsel for the petitioner submitted that when a suit for enforcement of charges is specified, no other Article could be looked into. The period prescribed therein is a longer one, ie. 30 years. That period is not yet over. The only further question is whether that Article can be pressed into service by Government. 10. Counsel for the petitioner submitted that when a suit for enforcement of charges is specified, no other Article could be looked into. That contention, I feel, will be doing violence to the interpretation of the wording contained in Art.112 of the Limitation Act. The term "any suit by the Government" is specifically dealt within various contexts. This is for an understandable reason. The reason has been discussed elaborately by the Supreme Court when the very constitutionality of that provision had been challenged before the Supreme Court, (vide ft. C. Jallv. Union of India & another, AIR 1962 S.C.1281). 11. It is trite saying that the State, as an administrative mechanism, requires, by its very nature, more favorable protection. It is run by human agencies. 'That the functioning of the human agencies is invariably ineffective, is sufficiently illustrated and demonstrated by this very case. It is in such circumstances, and to overcome the difficulties confronted by the State mechanism, that a special provision is intended and required for the State. The Supreme Court in R.C. Jail's case, has indicated the approach to be made in relation to the interpretation of the various provisions of the Limitation Act. Viewed that way, Article 112 should be interpreted in a liberal way promoting public interest, namely, conservation of revenue due to the State. In that view of the matter, Article 112 will take in any suit, whether it be in relation to recovery of money pure and simple, or for recovery of property ^or for enforcement of charge or for any one of these different species of litigation generally described in the schedule of the Limitation Act. This interpretation would certainly give a longer period of thirty years for enforcement of dues of the Court. In that view of the matter, the substantial and principal contention urged on behalf of the petitioner has to be repelled. I do so. 12. No other contention, which can be examined closely in proceedings under Art.226 of the Constitution, had been urged before this Court. 13. The writ petition, therefore, fails and is accordingly dismissed, but without any order as to costs. 14. This writ' petition was filed in the year 1986. I do so. 12. No other contention, which can be examined closely in proceedings under Art.226 of the Constitution, had been urged before this Court. 13. The writ petition, therefore, fails and is accordingly dismissed, but without any order as to costs. 14. This writ' petition was filed in the year 1986. As noted earlier, it related to the recovery of arrears of revenue, which fell due in the year 1966. The interim order passed by this Court, when it was uninformed about the various implications, impeded the recovery process. The State, however, did not assist the Court with timely information for the disposal of the case. It would appear that it took two years, for the State even to enter appearance in the case. Even thereafter, no counter-affidavit was filed in the case. It required a peremptory and detailed order, to prompt the Government to file the counter-affidavit. The order of the Court dated 17-10-88 indicated the numerous prayers made for adjourning the hearing, even after the case had been posted for hearing on2-5-1988. A hearing without the counter-affidavit could have been fatal to the interest of the revenue. The seriousness of the situation and the distressing delay experienced in similar matters prompted the Court to direct the Law Secretary to file a detailed affidavit explaining the reasons for such distressing delay in the filing of the counter-affidavit. 15. A counter-affidavit was filed thereafter on 9-11-1988. The Law Secretary too filed a counter-affidavit. 16. Some greater care taken in that behalf would have possibly helped avoiding the mistakes contained in the last sentence in paragraph 4, and the contradiction involved in the last two sentences in paragraph 6. 17. The fact that the Board of Revenue had received the notice on 18-12-1986 is admitted in the counter-affidavit. The matter had dragged on; and how even at the Governmental level, there has been unexplained inaction is indicated in paragraph 2 of the counter affidavit. Even after the receipt of the connected records, there had been undue delay. That is evident from paragraph 3. The facts stated in the affidavit, deserve to be noted by the Government at the highest level. A copy of the judgment will be forwarded to the Chief Secretary to Government.