SMT. SHYAM KISHORI DEVI vs PATNA MUNICIPAL CORPORATION & ANR.

The Supreme Court held that the order of the officer enhancing the valuation of the appellant's holding and rejecting the review petition was without jurisdiction under Section 107(1)(c) and Section 117(1) of the Bihar and Orissa Municipal Act, 1922. The Court clarified that the committee for review must consist of two tax-payers and a Deputy Magistrate, and that the burden of proof lies on the Commissioners to show that the previous assessment was incorrect due to fraud, misrepresentation, or mistake. The Court ruled that the notifications issued by the Government did not validly replace the committee as required by the Act.