Estate Duty recovery cannot continue after full payment is made and communicated to the Collector.

Recovery proceedings under the Estate Duty Act could not be sustained once the full estate duty had already been paid and that payment had been communicated to the Collector. On those admitted facts, the legal basis for further recovery action no longer existed, so continued coercive proceedings were unsustainable. A separate question about recovery charges was noticed, but it was not decided in the writ petition.

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Issues: Whether recovery proceedings under the Estate Duty Act could continue after the entire estate duty had been paid, and whether the petitioner remained liable to further recovery action.

Analysis: The admitted position was that the full duty had been paid and that this fact had been communicated to the Collector. In that circumstance, the basis for continuing recovery proceedings no longer survived. The possibility of separate recovery charges was noted, but that question was not decided in the writ petition.

Conclusion: The continued recovery proceedings could not be sustained after full payment of the duty, and the writ petition was allowed.

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