JUDGMENT : L. Rath, J. - The only question that falls to be decided in this case is the meaning of the phrase person aggrieved in Section 47-A(3) of the Indian Stamp Act (for brevity, referred to hereinafter as the Act'). The facts in a nut-shell are that the Petitioner purchased a piece of land with building standing thereon on 31-3-1980 for a consideration of Rs. 61,000/- through it registered sale deed from one Ratanlal Agarwal and two others. An objection was raised by the mother of opposite party No. 1 alleging under valuation of the property as also making a complaint that the vendors had no title to the property to sell the same. It was her case that the property originally belonged to Jodhraj, the brother of her maternal grand-father-in-law Bhabani Ram and that she was residing therein with her three sons. The vendor Ratanlal Agarwal also claims to be the doughter's son of Sambhu, son of Bhabani Ram. On such objection being raised, the District Sub Registrar referred the matter to opposite party No. 3, the Addl. District Magistrate who held that there was no under valuation of the property and dismissed the objection also holding that he had no authority to adjudicate the right, title and interest in respect of the property. As against such order the opposite party No. 1 carried an appeal before the District Judge, Sambalpur. The appeal was resisted by the Petitioner inter alia on the ground of focus stand of opposite party No. 1 to maintain the appeal as also on the merits. The learned District Judge overruled the objection of locus stand and holding the appeal to be maintainable and that the property had been under-valued, set aside the order of the Additional District Magistrate and fixed the value of the property at Rs. 1 lakh and answered the reference of the opposite party No. 2, the District Sub-Registrar, accordingly. Aggrieved by the judgment, the Petitioner has come before this Court. 2. Mr. Misra, learned Counsel for the Petitioner, has confined his Submissions to the sole question of maintainability of the appeal at the instance of opposite party No. 1 contending that no appeal lay at his instance and that further no objection was also entertainable at the instance of the mother of opposite party No. 1. 3. 2. Mr. Misra, learned Counsel for the Petitioner, has confined his Submissions to the sole question of maintainability of the appeal at the instance of opposite party No. 1 contending that no appeal lay at his instance and that further no objection was also entertainable at the instance of the mother of opposite party No. 1. 3. Section 47-A of the Indian Stamp Act., 1899 inserted by Orissa Act 35 of 1962 provides that when a document intending to transfer any property is presented for registration before the registering officer and he has reasons to believe that the value of the property or the consideration as set forth in the document is not true, he may refer the document after its registration to the Collector for determining the proper value or the consideration and the proper duty payable thereon. The Collector on receipt of the reference is to give the parties reasonable opportunity of being heard and after holding an enquiry in the prescribed manner, determine the value or consideration as also the duty payable and the deficit amount of duty so found payable has to be paid by the person liable to pay the same. Even without any reference made by the registering officer, the Collector has also the suo motu power to initiate a proceeding regarding any such document within two years from the date of the registration and determine the actual duty payable by the person liable to pay the same. Sub-section (3) of the section provides for a right of appeal in the following words: (3) Any person aggrieved by an order of the Collector under Sub-section (2) or Sub-section (2-a) may, within thirty days from the date of the order, prefer an appeal before the District Judge and all such appeals shall be heard and disposed of in such manner as may be prescribed by rules made under this Act. The very reading of the provision for appeal along with other provisions of the section pre-eminently shows the right of appeal to be personal of the person aggrieved. Both Sub-section (2) and (2-a) of Section 47-A speak of determination by the Collector of the amount of duty payable and on such determination the deficit duty becomes payable by the person liable to pay. Both Sub-section (2) and (2-a) of Section 47-A speak of determination by the Collector of the amount of duty payable and on such determination the deficit duty becomes payable by the person liable to pay. Hence a person aggrieved is a person against whom the determination has been made making him liable to pay the deficit amount of duty. Since the appealies only against the order passed by the Collector u/s and (2-a) and the only order contemplated under both the sub-sections is determination of the proper value or the consideration, it is manifest that the person who is aggrieved by such an order would be the one who would be liable under the section to pay the deficit duty. We are not deciding here the question as to whether the registering officer on whose reference the order is passed under Sub-section (2) of Section 47-A can also be treated as a person aggrieved since such question does not arise for consideration here. But in any view of the matter, a complete stranger to the non section can never be said to be a person aggrieved within the meaning of Sub-section (3). It may be that the registering officer decides to make a reference on information given to him by a stranger as in the present case, or the Collector may also initiate a proceeding suo motu on information lodged by a third party, but that by itself does not create a lis between the informer and the party to the instrument against whom the determination may be made and such position would also in no way alter even if the informer is heard by the Collector in the process of determination or is even allowed to lead evidence as has been done in the instant case. 4. The words person aggrieved' is a phrase which is often found in various statutes and has fallen for interpretation in various contexts. It is hazardous to make a formula inter petition of the phrase since, as has been noticed by variuos authorities, the meaning of the expression takes different hues in accordance with the context and the object of the Statute. Depending upon such factors, the expression may be amenable either to a restricted interpretation or to a wider one. The question was considered in Adi Pherozshah Gandhi Vs. Depending upon such factors, the expression may be amenable either to a restricted interpretation or to a wider one. The question was considered in Adi Pherozshah Gandhi Vs. H.M. Seervai, Advocate General of Maharashtra, Bombay, in connection with use of the phrase in Section 37 of the Advocates' Act, 1961 wherein the issue was whether the Advocate-General of a State, who appears before the disciplinary committee of a State Bar Council in pursuance of a notice given to him u/s 35(2), is a person aggrieved so as to maintain an appeal before the Bar Council of India against the decision of the disciplinary committee of the State Bar Council. Chief Justice Hidayatullah, referring to different authorities, held: From those cases it is apparent that any person who feels disappointed, with the result of the case is not a person aggrieved'. He must be disappointed of a benefit which he would have received if the order had gone the other way. The order must cause him a legal grievance by wrongfully depriving him of something. It is no doubt a legal grievance and not a grievance about material matters but his legal grievance must be a tendency to injure him. That the order is wrong or that it acquits some one who he thinks ought to be convicted does not by itself give rise to a legal grievance.... In coming to such conclusion, reliance was placed on (1880) 14 Ch. D. 458 (In re Side botham, Ex parte Side botham) where it was observed that a person aggrieved' is a person who is disappointed of a benefit which he might have received, if some order had been made and that he must have suffered a legal grievance, or a person against whom a decision has been pronounced which had wrongfully deprived him of something, or wrongfully refused him or wrongfully affected his title to something. Reliance was also placed on (1894) 1894 2 QB 805 (In re Lamb, Ex parte Board of Trade) wherein a distinction was made between a person who is brought before the Court to submit to its decision and a person who is heard in a dispute between others so that while the former can be said to be a person aggrived since he is in the nature of a party, the latter cannot be treated as such. The same view was also expressed in the judgment by Justice Matter speaking for himself and Justice Sheath. The decision was again considered in Bar Council of Maharashtra Vs. M.V. Dabholkar and Others, by a larger Bench of seven Judges where the expression was interpreted in the following words: ...The meaning of the words 'a person aggrieved' may, vary according to the context of the statute. One of the meanings is that a person will be help to be aggrieved by a decision if that decision is materially adverse to him. Normally one is required to establish that one has been denied or deprived of something to which one is legally entitled in order to make one a person aggrieved'. Again a person is aggrieved if a legal burden is imposed on him. The mining of the words a person aggrieved' is sometimes given a restricted meaning in certain statutes which provide, remedies for the protection of private legal rights. The restricted meaning requires denial or deprivation of legal rights. A more liberal approach is required in the background of statutes which do not deal with property rights but deal with professional conduct and morality xxxx The words person aggrieved' in Section 37 and 38 of the Act are of wide import and should not be subjected to a restricted interpretation of possession or denial of legal rights or burdens or financial interests. xxxx. Thus a distinction was drawn between a restricted meaning of the phrase and a necessity of a more liberal approach where an application is in the background of statute which does not deal with the property but with professional conduct and morality. From such authorities the position is clear that unless a person has suffered a legal injury or unless an order adverse to him affecting some of his own interests has been passed, he would not be a person aggrieved' so far as the Act is concerned. The opposite party No. 1 or his mother were certainly not persons brought before the authority vested with the power of determining the duty payable, so as to be bound by its decision. They only fulfilled the character of a person who was heard so as to facilitate the decision by the statutory authority. There was absolutely no lis between them and the person against whom the proceeding is initiated. 5. They only fulfilled the character of a person who was heard so as to facilitate the decision by the statutory authority. There was absolutely no lis between them and the person against whom the proceeding is initiated. 5. An authority which would be even more direct on the issue is Sri Ratnavaramaraja Vs. Smt. Vimla, which discussed whether the Defendant in a suit has a right of revision u/s 115 of the CPC against a determination by the Court regarding adequacy of the court-fee paid on the plaint. The case arose under the Madras Court-fees and Suits Valuation Act, 1955 wherein the Court held that whether proper court-fee is paid on a plaint is preliminary a question between the Plaintiff and the State and it is difficult to appreciate as to how a Defendant may feel aggrieved relating to the order regarding adequacy of the court-fee paid or otherwise. The Defendant who may believe even honestly that proper court-fee has not been paid by the Plaintiff, has still no right to move the superior Courts by appeal or in revision against the order adjuding payment of court-fee payable on the plaint. 6. While the decision of the Supreme Court was followed in 41 (1975) CLT 915 Mahadeolal Choudhury v. Hareram Choudhury and Ors. even before the decision of the Supreme Court this Court had taken the same view in ILR 1964 Cutt. 886 Sribastsa Panda v. Sitaram Padhi that the Court-fees Act was enacted to collect revenue for the benefit of the State and not to arm a contesting party with a weapon of defence to obstruct the trial of an action. The Defendant cannot make any grievance by seeking to invoke the revisional jurisdiction of the High Court on the question of adequate court-fee having been paid or not it beings primarily a question between the Plaintiff and the State. 7. Same as the court-fees payable on the plaint, the stamp duty payable on an instrument presented for registration is also ultimately to the benefit of the State and hence is primarily a question between the State and the person from whom the payment is to be realised. The position of opposite party No. 1 is not even similar to that of a Defendant in a suit who at least has a direct interest against the Plaintiff to contest the suit. 8. The position of opposite party No. 1 is not even similar to that of a Defendant in a suit who at least has a direct interest against the Plaintiff to contest the suit. 8. In that view of the matter, I must hold that the appeal before the District Judge by opposite party No. 1 was not maintainable. 9. The learned District Judge failed to appreciate the issue involved in the proper perspective and merely rejected the contention of locus stand holding that the objectors had been accepted as such since the beginning of the enquiry and their evidence had been accepted and they being citizens of the country had the right to challenge the valuation, which is a matter of public interest. Such considerations are wholly alien to the scope of the question. Merely because the mother of opposite party No. 1 had preferred an objection or had been allowed to lead evidence, it would not confer upon him or the mother the status of a 'person aggrieved' as has already been discussed and no right of appeal is also conferred upon opposite party No. 1 merely because he is a citizen. 10. In the result, the petition is allowed with costs and the impugned order in Annexure-6 is quashed. Hearing fee is assessed at Rs. 300/-. V. Gopalaswamy, J. 11. I agree. Petition allowed. Final Result : Allowed