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Issues: Whether a certificate issued by the Administrator General under Section 29 of the Administrator's General Act, 1963 could be treated as equivalent to a succession certificate from a court of law for release of arrear pension.
Analysis: The statutory scheme showed that a certificate under Section 29 is granted on a limited enquiry and on the basis of affidavits, subject to the restrictions in Sections 31 and 32. A succession certificate from a court of law, by contrast, follows a more elaborate procedure and affords protection against rival claims. The two certificates are not interchangeable in law, and the authority was justified in insisting on the court-issued succession certificate where the governing rules required legal authority for payment of the amount.
Conclusion: The certificate issued by the Administrator General could not be equated with a succession certificate from a court of law, and the insistence on a court succession certificate was lawful.
Final Conclusion: The writ petition failed and the challenge to withholding of arrear pension was rejected.
Ratio Decidendi: A certificate issued by the Administrator General under Section 29 of the Administrator's General Act, 1963 is not equivalent to a succession certificate issued by a court of law, and where the applicable payment rules require such legal authority, the claimant cannot substitute the former for the latter.