JUDGMENT : The petitioner is a society registered under the Madhya Pradesh Society Registrikaran Adhiniyam, 1973. It is running an educational institution Jyoti Senior Secondary School, Rewa in a building and land within the limits of Municipal Corporation, Rewa. The certificate dated 13-1-2000, Annexure P-15, issued by the Tehsildar, Rewa confirms that the land on which Jyoti Senior Secondary School has been constructed also belongs to it. In the present petition, the petitioner has challenged the validity of demand notices (Annexures P-2 and P-5) issued to it by the Municipal Corporation, Rewa for payment of property tax relating to the land and building of the Jyoti Senior Secondary School. 2. The case of petitioner is that since it is using building and land exclusively for educational purposes, it is exempted from the levy of property tax under Section 136 (c) of the Municipal Corporation Act, 1956 (in short, "the Act") and, therefore, the impugned demand notices for payment of property tax being bad in law be quashed. 3. The Municipal Corporation, Rewa, in reply has defended the validity of demand notices for the property tax on the ground that petitioner, being a private educational institution is imparting education after charging fee and, therefore, it is not exempted from levy of property tax under Section 136 (c) of the Act. A plea has also been taken for the dismissal of petition in view of the availability of alternative remedy of appeal to the petitioner under Section 149 of the Act against the demand of property tax. 4. The main question which calls for consideration is whether the petitioner's educational institution Jyoti Senior Secondary School is exempted from levy of property tax. 5. Chapter XI of the Act deals with taxation by Corporation. Sections 132, 133, 135 and 136 of the Act with which I am concerned occur in this chapter. Section 132 (1) relates to taxes which the Corporation must impose. Its relevant sub-section (1) (a) reads as under :- "132. Taxes to be imposed under this Act. 5. Chapter XI of the Act deals with taxation by Corporation. Sections 132, 133, 135 and 136 of the Act with which I am concerned occur in this chapter. Section 132 (1) relates to taxes which the Corporation must impose. Its relevant sub-section (1) (a) reads as under :- "132. Taxes to be imposed under this Act. - (1) For the purpose of this Act, the Corporation shall, subject to any general or special order which the State Government may make in this behalf, impose in the whole or in any part of the Municipal Area, the following taxes, namely :- (a) a tax payable by the owners of building or lands situated within the city with reference to the gross annual letting value of the buildings or lands, called the property tax, subject to the provisions of Sections 135, 136 and 138." 6. Section 133 of the Act provides a procedure to be adopted by the Corporation while imposing any tax. Section 135 deals with the rate at which property tax can be imposed by the Corporation for each financial year. Section 136 provides for exemption from levy of property tax under Section 135. The relevant clause (c) of Section 136 reads as under :- "136. Exemptions.- The property tax levied under Section 135 shall not be leviable in respect of the following properties, namely :- (c) buildings and lands or portions thereof used exclusively for educational purposes including schools, boarding houses, hostels and libraries if such buildings and lands or portions thereof are either owned by the educational institutions concerned or have been placed at the disposal of such educational institutions without payment of any rent.'' 7. A bare reading of the above referred provisions clearly establishes that property tax is one of the taxes which the Corporation must impose but the imposition of this tax is subject to the provisions of Sections 135 and 136. Clause (c) of Section 136 also clearly states that exemption from levy of property tax applies to all the buildings and lands or portions thereof used exclusively for educational purposes. The only restriction is that buildings and lands should be owned by the educational institutions concerned or placed at the disposal of such educational institutions without payment of any rent. Clause (c) of Section 136 also clearly states that exemption from levy of property tax applies to all the buildings and lands or portions thereof used exclusively for educational purposes. The only restriction is that buildings and lands should be owned by the educational institutions concerned or placed at the disposal of such educational institutions without payment of any rent. There is no express provision in the clause that exemption will not apply to private educational institution which is imparting education and while doing so it is making profit. It is also not possible to read such an implied provision in the exemption clause. The expression used "exclusively for educational purposes" is wide enough to cover use for education by private schools. For these reasons, I have no hesitation in holding that the petitioner's educational institution Jyoti Senior Secondary School is exempted from the imposition of property tax in respect of building and land used by it exclusively for educational purposes. 8. As regards the plea taken by the Municipal Corporation, Rewa, for the dismissal of the petition on the ground of availability of alternative remedy to file appeal before the District Court under Section 149 of the Act, I am of the view that provision for appeal does not take away the jurisdiction of High Court conferred under Article 226 of the Constitution. It is a matter of discretion of the High Court to interfere or not to interfere in case of such a provision. It is to be noted that, the present petition was entertained in the year 2007 and return has been filed. The petition involves a question whether the use of building and land by educational institution for education is covered under the exemption clause (c) of Section 136 of the Act from levy of property tax. In these circumstances, I do not think that it will be a proper exercise of discretion to throw away the petition because of the provision for appeal. 9. The petition is allowed and the demand notices (Annexures P-2 and P-5) for property tax relating to the building and land of Jyoti Senior Secondary School used exclusively for educational purposes are quashed. No order as to costs.