Fresh objections after substitution in certificate proceedings are barred once liability issues are concluded, with remedy confined to property claims.

Substituted legal representatives added after the objection stage in a certificate proceeding under the Orissa Public Demands Recovery Act cannot reopen objections to liability or executability by seeking a fresh notice and fresh opportunity under section 10 once the matter has passed the stages covered by sections 8 and 9 and the properties have been advertised for sale. The proviso to section 10 was held not to extend to re-agitating concluded objections at that late stage, as doing so would defeat the statutory scheme. Where new properties are proceeded against, the proper remedy lies under section 20 in relation to attachment or sale of property claimed not to be liable.

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Issues: Whether heirs substituted after the objection stage in a certificate proceeding under the Orissa Public Demands Recovery Act were entitled to a fresh notice and a fresh opportunity to file objections under section 10.

Analysis: The proceeding had already passed the stage contemplated under sections 8 and 9, and the properties had been advertised for sale when the legal heirs were substituted. Section 10, including its proviso requiring fresh notice after amendment, was held not to permit reopening of objections already concluded. Allowing a substituted heir to re-raise liability and executability issues at that stage would defeat the scheme of the Act. The proper remedy, if new properties were proceeded against, would lie under section 20 in relation to attachment or sale of property claimed to be not liable.

Conclusion: The substituted heirs were not entitled to fresh objections or fresh notice under section 10 at that late stage, and the writ petition failed.

Ratio Decidendi: Substituted legal representatives added after the objection stage in a certificate proceeding cannot reopen concluded objections to liability or executability by invoking section 10, though they may pursue objections under section 20 where new properties are sought to be attached or sold.

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