Execution of public demand certificates can include accrued interest despite payment of principal under the statutory scheme.

A certificate signed and filed under the Bihar and Orissa Public Demands Recovery Act, 1914 operates as a decree and remains executable subject to the Act. Section 17(a) expressly permits recovery in execution of interest on the public demand from the date of the certificate until realisation at the prescribed rate, so the certificate-holder may recover accrued interest even after the principal amount is paid. Section 32 concerns only the distribution of execution proceeds and claim priorities; it does not limit the substantive right created by section 17(a).

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Issues: Whether interest on the certificate amount was recoverable in execution under the Bihar and Orissa Public Demands Recovery Act, 1914, even after the certificate-debtor paid only the principal amount.

Analysis: A certificate signed and filed under section 6 of the Bihar and Orissa Public Demands Recovery Act, 1914 has the effect of a decree and is executable subject to the Act. Section 17(a) expressly authorises recovery in execution of interest on the public demand from the date of signing of the certificate until realisation at the prescribed rate. Section 32 deals only with the mode of disposal of execution proceeds and priorities among claims; it does not curtail the substantive right to recover interest created by section 17(a). The liability to pay accrued interest therefore continues notwithstanding payment of the principal amount, and the certificate-holder may realise such interest in execution.

Conclusion: The interest was recoverable in execution, and the appellant remained liable for accrued interest.

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