ARVIND, MEMBER–These two revision petitions have been filed under Section 56 of the Indian Stamp Act, 1899 read with Rajasthan Stamp Law (Adaptation) Act, 1952 against the order dated 17.9.2004 passed by the learned Addl. Collector (Stamps), Jaipur. (2). Since the facts and law points involved in both these cases are similar and the issues to be decided are same, hence, both the cases are heard and decided together and decision may be enclosed in both the files. (3). The brief facts are as under: The petitioner Navjeevan Builders/Navjeevan Developers have sought to challenge the order dated 17.9.04 passed in application No. 476/94 and No. 478/94 under Section 47-B of the Indian Stamp Act. The Addl. Collector, Jaipur exercising the power of the Collector (Stamp) had levied stamp duty and penalty of Rs. 73, 93, 520/- on each of the instruments presented by the petitioner company for registration against sale deeds presented for registration. Having aggrieved by the order dated 17.9.04 by which earlier order were confirmed the petitioner company has sought to challenge the order passed by the learned Addl. Collector (Stamp) dated 17.9.2004. (4). The present revision petitions were presented to the Board of Revenue on 15.10.2004. On presentation objection was raised in the Board of Revenue that the revision petitions have not been supported by a satisfactory proof of the payment of fifty percent of the recoverable amount. The State Government has also come up with the objection that the revision petitions cannot be entertained for hearing unless a condition under section 65 of the payment of 50% of the recoverable amount is fulfilled. (5). The petitioner company argues that it is not required to deposit any advance payment before the petitions are entertained for hearing. The contention of the petitioner in both petitions is that the petitions have been presented before the Board of Revenue under Section 56 of the Indian Stamp Act, 1899 read with Rajasthan Stamp Law adoption Act, 1952 (which we will mention as old Act hereinafter) and the contention of the advance payment of 50% before entertaining the petitions for hearing has been brought in by the Rajasthan Stamp Act, 1998 (hereinafter mentioned as new stamp Act) and such a condition did not exist in the Old Act. These petitions at this stage were heard on the issue whether the petitions can be entertained for hearing without the condition of payment in advance of the 50% of the recoverable amount. (6). The learned advocate argued that the matters were decided by the learned Addl. Collector (stamps) Jaipur on 17.9.04 by which the orders dated 3.1.1998 were upheld. On a report of the Sub- Registrar cases of deficit stamp duty were registered by the learned Addl. Collector and the learned Addl. Collector decided the cased on 3.1.1998. We further made an application before the Addl. Collector and which was not decided and we approached the Honble High Court and sought directions for awarding us opportunity of hearing. The learned Addl. Collector on hearing us deciding the mater again on 17.9.2004 and in that orders he confirmed the earlier order passed by his predecessor in which sum of Rs. 73,93,520/- was ordered to be paid by us to the Government in both the cases. (7). The learned counsel for the petitioner argues that these cases were decided by learned Addl. Collector under the old law and we are entitled for getting the advantage of further proceedings under the old law. We have not presented the petitions under the new stamp law. Hence, all rules and conditions which exist under the old law will be applicable on our petitions and the conditions under the new law will not be applicable to us. Learned counsel invited our attention to the judgment of Honble Supreme Court reported in S.C.C. Volume VI 2003 page 56 and S.C.C. 2004 Volume page 551. (8). Learned counsel for the petitioner argued that the proceedings are continuing under the old law, hence, we are not supposed to come under the new law. He also argued that there are number of decision of the Honble Supreme Court in which it has been decided that a statute is to be applied prospectively and it cannot be applied retrospectively. In this respect our attention was invited to S.C.C. 2004 Volume 5 page 618. He also argued that this case is supported by Section 6 of the General Clauses Act in which the repeal does not affect our legal proceedings. Even when there is not specific mention of a remedy under the new law it will be presumed that the provision of the old law will be applicable in the pending matters. He also argued that this case is supported by Section 6 of the General Clauses Act in which the repeal does not affect our legal proceedings. Even when there is not specific mention of a remedy under the new law it will be presumed that the provision of the old law will be applicable in the pending matters. (9). Replying to the arguments of learned counsel for the petitioner the learned Government Advocate argued that the contention of the revision petitioner are neither legal nor proper because the decision passed by the learned Addl. Collector has been passed on 17.9.2004 and the revision petition have been filed against the order dated 17.9.2004. On the date on which the decision was passed by the learned Addl. Collector the new stamp act had come into existence and no revision can be brought against this order under the old law. (10). Learned Government Advocate also argued that the petitioner has no vested rights in the course of a revision petition because revision does not give any vested rights to a litigant but it is the right of the court to examine the legality, or property of an order of a subordinate court. All the rulings cited by the learned counsel for the petitioner have discussed the matters which came before Honble Courts during the course of appears the trial or under an investigation in any subordinate court. The decision has been passed by learned Addl. Collector on 17.9.2004 and on the date of passing of that decision the new Act had already come into force. There is no provision of any appeal against the decision of the Addl. Collector and the petitioner has come with a revision petition and a revision petition does not given them any vested right of any advantage under the old law. When the new law has come into existence and there is a clear provision of a revision under the new law, there is alternate remedy, available with the petitioner and the petitioner has an opportunity of bringing his petition under Section 65 of the new Stamp Act and not under 56 of the old law. When the new law has come into existence and there is a clear provision of a revision under the new law, there is alternate remedy, available with the petitioner and the petitioner has an opportunity of bringing his petition under Section 65 of the new Stamp Act and not under 56 of the old law. Under Section 65 of the New Act the revision petitioner has to deposit the desired amount when there is a clear provision of law under the new Act and as such the revision petitions cannot be filed under Section 56 of the old stamp Act. Under Section 56: the advantage of the pending proceedings could have been taken only when the matter was not completed by a subordinate courts but in this case the matter has already been finally decided by the learned Addl. Collector. He also argued that the right of revision is not a vested right as it is available under an appeal. (11). In support of the arguments made above the learned Government Advocate invited our attention to more than half a dozen decisions made by the Honble Board of Revenue. Following decisions were cited. 1. Revision/495/2004/Sirohi/Stamp 2. Revision/496/2004/Sirohi/Stamp 3. Revision/497/2004/Sirohi/Stamp 4. Revision/498/2004/Sirohi/Stamp 5. Revision/499/2004/Sirohi/Stamp 6. Revision/500/2004/Sirohi/Stamp 7. Revision/501/2004/Sirohi/Stamp 8. Revision/578/2004/Jaipur/Stamp (12). He further argued that the issues raised in the course of arguments in the petitions mentioned above have been elaborately discussed and the petitioners get not advantage from the conclusions therein. (13). In view of the above discussions the key point to be decided in whether the benefit of continuity of proceedings under the law is to be given to the petitioner or not under the old law. The cases referred by the petitioner are not directly relevant to the matter in the present revision petitions as those are cases either of appeals or of pending trials. In this reference it is very relevant to mention ``D.B. judgment of Honble Supreme Court in Shiv Shakti Cooperative Housing Society vs. Swaraj Developers and others. In this case Honble judges have thrown light on how an appeal basically differs from a revision and also that it is an appeal that gives a vested right. This is not a case of appeals but of revision petitions. In this case Honble judges have thrown light on how an appeal basically differs from a revision and also that it is an appeal that gives a vested right. This is not a case of appeals but of revision petitions. Honble Judges have also discussed how and when the principle of prospective application will be applied, the issue of the interpretation of the statutes and matters which are primary issues in these petitions also find greater relevance. It would be appropriate to give the extracts from the decision of this case. ``An appeal is essentially continuation of the original proceedings and the provisions applied at the time of institution of the suit are to be operative even in respect of the appeals. That is because there is a vested right in the litigant to avail the remedy of an appeal. As was observed in K.Kapen Chako V. Provident Investment Co. (P)Ltd. Only in cases where vested rights are involved, a legislation has to be interpreted to mean as one affecting such right to be prospectively operative. The right of appeal is only by statute. It is (sic not a) necessary part of the procedure in an action, but ``the right of entering a superior court and invoking its aid and interposition to redress the error of the court below. It seems absurd to denominate this paramount right part of the practice of the inferior tribunal. (Per Lord Westbury, See: Attorney General vs. Sillem ER P. 1209). The appeal, strictly so called, is ``one in which the question is, whether the order of the court from which the appeal is brought was right on the materials which that court had before it (Per Lord Devuil Ponnammal vs. Armogam. The right of appeal, where it exists, is a matter of substance and not of procedure (Colonial Sugar Refining Co. vs. lrving). As was observed in State of Kerala vs. K.M. Charia Abdulla and Co. the distinction between right of appeal and revision is based on differences implicit in the two expressions. An appeal is continuation of the proceedings; in effect the entire proceedings are before the Appellate Authority and it has the power to review the evidence subject to statutory limitations prescribed. the distinction between right of appeal and revision is based on differences implicit in the two expressions. An appeal is continuation of the proceedings; in effect the entire proceedings are before the Appellate Authority and it has the power to review the evidence subject to statutory limitations prescribed. But in the case of revision, whatever powers the revisional authority may or may not have, it has no power to review the evidence, unless the statute expressly confers on it that power. It was noted by the four Judge Bench in Hari Shankar vs. Rao Girdhari Lal Chaudhary that the distinction between an appeal and a revision is a real one. A right of appeal carries with it a right of rehearing on law as well as fact, unless the statute conferring the right of appeal limits the rehearing in some way, as has been done in second appeals arising under in Code. The power of hearing revision is generally given to a superior court so that if may satisfy itself that a particular case has been decided according to law. It is a well settled principle in law that the Court cannot read anything into a statutory provision which in plain and unambiguous. A statute is an edict of the legislature. The language employed in a statute is the determinative factor of legislative intent. Words and phrases are symbols that stimulate mental references to referents. The object of interpreting a statute is to ascertain the intention of the legislature enacting it. (See Institute of Chartered Accountants of India vs. Price Waterhouse.) The intention of the legislature is primarily to be gathered from the language used, which means that attention should be paid to what has been said as also to what has not been said. As a consequence, a construction which requires for its support, addition or substitution of words or which results in rejection of words as, meaningless has to be avoided. As observed in Crawford vs. Spooner courts cannot aid the legislatures defective phrasing of an Act, we cannot add or mend, and by construction made up deficiencies which are left there, (see State of Gujarat vs. Dilipbhai Nathjibhai Patel). It is contrary to all rules of construction to read words into an Act unless it is absolutely necessary to do so. It is contrary to all rules of construction to read words into an Act unless it is absolutely necessary to do so. (See Stock vs. Frank Jones (Tipton) Ltd. Rules of interpretation do not permit courts to do, unless the provision as it stands is meaningless or of a doubtful meaning. Court are not entitled to read words into an Act of the Parliament unless clear reason for it is to be found within the four corners of the Act itself. (Per Lord Loreburn, L.C. in Vickers Sons and Maxim Ltd. V.Evans, quoted in Jamma Masjid vs. Kodimaniandra Deviah.) Section 6 of the general Clauses Act has no application because there is no substantive vested right available to a party seeking revision under Section 115 of the Code. In Kolhapur Cane Sugar Works Ltd. vs. Union of India it was observed that if a provision of statute is unconditionally omitted without a saving clause in favour of pending proceedings, all actions must stop where the omission finds them, and if final relief has not been granted before the omission goes into effect, there is no scope for granting it afterwards. There is modification of this position by application of section 6 of the General Clauses Act or by making special provisions. Operation of repeal or deletion as to the future and the past largely depends on the savings applicable. In a case where a particular provision in the statute is omitted and in its place another provision dealing with the same contingency is introduced without a saving clause in favour of pending proceedings, then it can be reasonably inferred that the intention of the legislature is that the pending proceedings shall continue but a fresh proceedings for the same purpose may be initiated under the new provision. In view of what has been stated above, the inevitable conclusion is that the High Court were right in the conclusion about non-maintainability of revision applications. It was submitted by learned counsel for the appellants that even if the revision applicants are held to be not maintainable, there should not be a bar on challenge being made under Article 227 of the Constitution. It was submitted that an opportunity may be granted to the appellants to avail the remedy. If any remedy is available to a party under any statute no liberty is necessary to be granted for availing the same. It was submitted that an opportunity may be granted to the appellants to avail the remedy. If any remedy is available to a party under any statute no liberty is necessary to be granted for availing the same. If the appellants avail such remedy, the same shall be dealt with in accordance with law. (14). With all humility and profound respect to the discussions and conclusions quoted from the decisions of Honble Supreme Court as above the matter can be summed up as under:- (i) There is no ambiguity in the sections 65 and 91 of the new Act which may attract our attention to seek help from the General Clauses act. (ii) The present revision petition is not a continuation of the proceedings in the present matter and hence, the benefit under the old law can not be considered. (iii) This is a revision and revision does not confer a vested right which is available in a appeal. the petitioner cannot therefore claim any vested right in a revision for claiming continuity of legal proceedings when a clear provision under Section 65 of the new Act is available. Honble Supreme Court has laid down a principle that appeal is a vested right but a revision does not find inclusion for that purpose. iv) The judgment passed by the learned Addl. Collector (Stamp), Jaipur was passed after the new act came into force. v) in a revision it is largely a prerogative and discretion of the court to examine the legality and propriety of the orders passed by the subordinate courts and on this issue petitioner can have no claim of continuity of the proceedings under the old law. (Referred Ram Kanai etc. (Pvt.) Ltd. vs. Board of Revenue (1976(3) See PP 374-375). vi) it is clear from the discussion above that there is neither any case pending under trial or investigation in any subordinate court and also there is no appeal against on order under the old act. Honble Supreme Court in a decision reported by AIR 1965 SC Pt. III page 1585 has laid down a principle of an essential distinction between an appeal and a revision. `` An appeal is a continuation of the proceedings, revision is not. vii) The legislation has given a specific provision under Section 65 of new Stamp Act the benefit of which can be taken by the petitioner. III page 1585 has laid down a principle of an essential distinction between an appeal and a revision. `` An appeal is a continuation of the proceedings, revision is not. vii) The legislation has given a specific provision under Section 65 of new Stamp Act the benefit of which can be taken by the petitioner. The advance deposit does not mean that the money will not be refunded. The stamp duty can be refunded to the petitioner in case the petition succeeds. viii) Under Section 65 of the new Act the legislation suggests nothing which says that in case like this, there will be an exception from advance deposit 50% of the recoverable amount. (15). In view of the judgment of the Honble Supreme Court in Shiv Shakti Supra case it cannot be accepted that this revision petition can be accepted for hearing under Section 56 of the old Act. (16). In view of the discussions above I find that this revision petition cannot be entertained for hearing without deposition of payment of 50% of the recoverable amount in advance and the petitions are therefore, not entertained for hearing and consequently both the revision petitions are rejected. Pronounced in the open court.