Belated revenue recovery charge against a subsequent purchaser cannot stand after prolonged inaction and lack of effective recovery steps.

A belated revenue recovery notice asserting a charge over attached property was held unsustainable against a subsequent purchaser where the authorities had not diligently completed the recovery process. The property remained under attachment, but no effective auction or further recovery action was taken for many years, and the petitioner purchased without knowledge of any subsisting charge. As the notice was issued long after the sale and after prolonged inaction by the authorities, the attempt to enforce the recovery charge against the petitioner was quashed.

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Issues: Whether the impugned notice asserting a tax recovery charge over the property could be sustained against a subsequent purchaser after long delay in completing recovery proceedings.

Analysis: The property had been attached in revenue recovery proceedings, but the authorities did not proceed diligently to auction the property or complete recovery. The defaulter sold the property to a second purchaser, who in turn sold it to the petitioner, and no effective further action or notice was taken for many years. The petitioner purchased the property without knowledge of any subsisting charge, and the notice was issued long after the sale. In these circumstances, the belated attempt to enforce the recovery charge against the petitioner was held unsustainable.

Conclusion: The impugned notice could not be sustained and was quashed in favour of the petitioner.

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