ORDER : Heard the learned counsel for the petitioner and the learned AGA and the learned counsel for the third respondent. 2. The petitioner is before this Court in this writ petition being aggrieved by the order of the KSAT, Bengaluru, dated 11.10.2022 rendered in Application No.1591/2021. 3. The brief facts are that the petitioner was discharging duties as a Sub Registrar in the office of the Sub Registrar at Jayanagar. During the year 2016 one Sri B N Vishwanath presented a Deed of Revocation of General Power of Attorney dated 17.02.2016 thereunder revoking the General Power of Attorney dated 07.08.2013. It was a unilateral revocation and it was a GPA executed in favour of a developer/builder. The petitioner demanded a stamp duty of Rs.200/- and Rs.100/- towards registration charges and completed the procedure of cancellation. 4. One Ramanalal M Shah in whose favour the GPA was originally executed lodged a complaint alleging that the cancellation of the GPA is illegal and that the same has caused loss to the exchequer and that the cancellation is unilateral and without the interference of any Court. The Lokayuktha took up the investigation and prepared a report under Section 12(1) of the Karnataka Lokayuktha Act, 1984 and a report dated 23.08.2019 was submitted to the State. While submitting the report the Lokayuktha recommended as under: “9. Further it is noted that Rule 170 of the Karnataka Stamp Rules, 1965, provides that when owing to sheer carelessness or ignorance of the Stamp Act, a Sub- Registrar accepts and registers an deed on which insufficient duty has been paid, the loss to Government may be ordered to be made good by the Sub-Registrar, on the final orders of the Inspector General of Registration, after which, the deficit items shall be taken to the prescribed Demand Register. Under the circumstances, it would proper to send recommendation under section 12(1) of the Karnataka Lokayukta Act, 1984 to the Competent Authority for taking action to make good the loss caused to the Government due to the acceptance and registration or Deed of Revocation of GPA dated 17/02/2016, by the respondent, on which insufficient stamp duty has been paid.” 5. In effect the Lokayuktha appreciating Rule 170 of the Karnataka Registration Rules, 1965 has recommended that the opinion of the Inspector General of Registration be secured and thereafter to initiate steps to recover the loss. In effect the Lokayuktha appreciating Rule 170 of the Karnataka Registration Rules, 1965 has recommended that the opinion of the Inspector General of Registration be secured and thereafter to initiate steps to recover the loss. The opinion appears to be based on the contents of Rule 170. Rule 170 of the Karnataka Registration Rules, 1965 reads as under: “170. COLLECTION WHEN INSUFFICIENT STAMP DUTY HAS BEEN PAID.- (i) When owing to sheer carelessness or ignorance of Stamp Act, a Sub- Registrar accepts and registers a deed on which insufficient duty has been paid, the loss to Government may be ordered to be made good by the Sub-Registrar, on the final orders of the Inspector General of Registration, after which, the deficit items shall be taken to the prescribed Demand Register. PROVISO.-If there is a controversy between the Inspecting Officer and Registering Officer regarding the Classification of the document and the stamp duty leviable, the matters shall be submitted to the Inspector General of Registration with the relevant authority, rule or case law on the subject and the inspector General’s orders thereon shall be final. (ii) In cases of neglect in the levy of registration fees, the Inspector General of Registration, will, while passing final orders on the inspection notes, order, on the merits of the case, that the deficit in fees should be made good by the Sub-Registrar concerned if it cannot be recovered from the parties. The inspectors of Registration will indicate such cases in their inspection notes for the inspector General’s orders. (iii) The under charged fee ordered by the Inspector General to be made good by the Sub-Registrar at fault should be made good within three months from the date of receipt of the order or before handing over charge of the office on transfer, whichever is earlier. (iv) There is no provision under the Stamp Act under which a Registering Officer can compel or demand the production of an insufficiently stamped document, for the purpose of impounding it. An intimation that the document is sufficiently stamped should be given to the party concerned who should be left to take whatever action he thinks fit.” 6. On a reading of the rules, the mandate of the rule is apparent. It stipulates that the act ought to be a result of carelessness or in ignorance of the statute. An intimation that the document is sufficiently stamped should be given to the party concerned who should be left to take whatever action he thinks fit.” 6. On a reading of the rules, the mandate of the rule is apparent. It stipulates that the act ought to be a result of carelessness or in ignorance of the statute. In such an event, it casts an obligation on the Sub-Registrar to make good to the State the loss suffered. The provisions stipulate that in the event there is a dispute between the investigating officer and the registration officer regarding classification of the document and the stamp duty leviable, the matter shall be submitted to the IGR. Sub Rule (ii) further stipulates that the liability can be cast on the officer only in the event of it being irrecoverable from the parties. 7. Admittedly in the instant case on hand there has been no reference to the IGR, no adjudication by the IGR and no classification of the document is undertaken by any one, muchless the IGR, nor is the deficit stamp duty assessed by the competent authority. Despite this glaring lacunae the respondent State has called upon the petitioner to make good the loss. Apparently no audit objections have been raised. Probably if audit objections had been raised the petitioner would have been alerted and probably he might have taken steps to recover the same. On a reading of the order it is apparent that though the authority was made aware of the mandate of Rule 170, the authority has blindly brushed it aside and right away called upon the petitioner to pay the sum. The Tribunal after appreciating the facts has proceeded to appreciate the contents of the documents and has concluded that it was an instrument that was required to be stamped and the stamp duty was also calculated at Rs.7,58,000/- and after taking note of the misconduct deemed it fit to brush aside the case canvassed on behalf of the applicant. Our observations are fortified by the observations made and findings rendered by the Tribunal in paragraphs 7 to 10. 8. In our opinion, the Tribunal has misled itself. Our observations are fortified by the observations made and findings rendered by the Tribunal in paragraphs 7 to 10. 8. In our opinion, the Tribunal has misled itself. The Tribunal was required to look in as to whether the act is performed in accordance with the law of the land, namely, the Karnataka Registration Rules, 1965 and as to whether the respondent State has atleast acted in accordance with the directions of the Lokayuktha. 9. Prima facie we find that, the procedures stipulated under the Act or Rules has not been complied with. Section 45A of the Stamp Act provides for the mechanism while dealing with cases of under-valuation. Rule 170 of the Karnataka Registration Rules, 1965 provides for a specific instance of escapement of stamp duty on account of a negligent act or on account of ignorance by the Sub Registrar. 10. In the case on hand there is no enquiry either under Section 45A or muchless under Rule 170. Proviso to sub rule (i) mandates that in the event of a disagreement on the valuation, matter is required to be referred to the IGR; and sub rule (ii) mandates that the loss shall be made good only if the amount cannot be recovered from the parties. The added dimension in the instant case is that no efforts have been made to recover the amount from the parties. 11. Be that as it may, we are not entering upon the merits of the matter. It is trite law that when the statute mandates an act to be performed in a particular manner the said act shall be performed in the said manner or not at all. In this regard this Court places reliance on the pronouncements of the Hon’ble Apex Court rendered in the case of State of Bihar and Another vs. J A C Saldanha and Others, (1980) 1 SCC 554 in paragraph 17, it is observed as under: “17. …. It was incidentally submitted that it is an undisputed dictum of law that when a statute requires a thing to be done in a certain manner it shall be done in that manner alone and the court would not expect its being done in some other manner (see State of Gujarat v. Shantilal Mangaldas). …. It was incidentally submitted that it is an undisputed dictum of law that when a statute requires a thing to be done in a certain manner it shall be done in that manner alone and the court would not expect its being done in some other manner (see State of Gujarat v. Shantilal Mangaldas). Expounding the submission it was stated that sub-section (8) of Section 173 clearly indicates the power of further investigation after submission of a report and that power is conferred on the officer in charge of a police station only and, therefore, the State Government was incompetent to direct further investigation. It was further contended that in view of the provision contained in Section 173(8) it would not be open to the court to so interpret the word “superintendence” in Section 3 of the Police Act as to empower the State Government to direct investigation being done by some one other than the statutory authority envisaged by Section 173(8) because such an interpretation would derogate from the principle that where a thing is required by a statute to be done in a particular way it shall be deemed to have prohibited that thing being done in any other way. In Ex parte Stephen the principle is stated that if a statute directs a thing to be done in a certain way that thing shall not, even if there be no negative words, be done in any other way. Subba Rao, J. in Patna Improvement Trust v. Smt Lakshmi Devi spelt out the combined effect of the aforementioned principles thus: “A general Act must yield to a special Act dealing with a specific subject-matter and that if an Act directs a thing to be done in a particular way, it shall be deemed to have prohibited the doing of that thing in any other way.”” 12. In the instant case there is neither a reference to the IGR nor an evaluation by the IGR or any objections by the audit authorities and without following the procedure set out under law the impugned demand has been raised on the petitioner. The petitioner also raises an additional objection that the 12(1) report itself is not maintainable in view of the fact that no injustice has been caused to the complainant. The petitioner also raises an additional objection that the 12(1) report itself is not maintainable in view of the fact that no injustice has been caused to the complainant. Be that as it may, having noticed several incongruities and the lacunas and the fact that the demand is not in consonance with the provisions of Rule 170, we deem it appropriate to set aside the same and further remit the matter back to the first respondent to re-do the exercise in accordance with law. 13. The matter is remitted back by leaving all contentions open. The first respondent shall afford an opportunity to the petitioner and after hearing the petitioner shall proceed to re-do the exercise without being influenced by the observations. 14. In view of disposal of the main petition, pending applications, if any, do not survive for consideration and hence disposed of.