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General Fibre Dealers Ltd. Vs. Income-tax Officer and ors. - Court Judgment

LegalCrystal Citation
SubjectDirect Taxation
CourtKolkata High Court
Decided On
Case NumberMatter No. 396 of 1977
Judge
Reported in[1979]116ITR40(Cal)
ActsConstitution of India - Articles 32 and 226(3); ;Income Tax Act, 1961 - Sections 143, 154, 214, 214(1) and 264; ;Constitution of India (Amendment) Act - Article 226
AppellantGeneral Fibre Dealers Ltd.
Respondentincome-tax Officer and ors.
Appellant AdvocateBhaskar Gupta, Adv.
Respondent AdvocateSuhas Sen and ;Samar Banerji, Advs.
Cases ReferredAhmedabad Cotton Manufacturing Co. v. Union of India
Excerpt:
- sabyasachi mukharji, j.1. in this matter, i had delivered judgment on 24th & 28th november, 1977, but before i could sign the judgment, learned advocate for the petitioner submitted that he wanted to make some further submissions. accordingly, i recalled the judgment and heard learned advocates for both sides on certain points.2. the general fibre dealers ltd. filed their return of income under the i.t. act, 1961, for the assessment year 1966-67 on or about 8th of august, 1966. in the said return, the said firm, which is the petitioner herein, declared an income of rs. 9,54,582. the petitioner-company claimed set-off of the loss of rs. 5,80,331. the ito on or about 18th of august, 1970, assessed the total income to be rs. 3,53,568. the tax payable was determined at rs. 2,29,574. the.....
Judgment:

Sabyasachi Mukharji, J.

1. In this matter, I had delivered judgment on 24th & 28th November, 1977, but before I could sign the judgment, learned advocate for the petitioner submitted that he wanted to make some further submissions. Accordingly, I recalled the judgment and heard learned advocates for both sides on certain points.

2. The General Fibre Dealers Ltd. filed their return of income under the I.T. Act, 1961, for the assessment year 1966-67 on or about 8th of August, 1966. In the said return, the said firm, which is the petitioner herein, declared an income of Rs. 9,54,582. The petitioner-company claimed set-off of the loss of Rs. 5,80,331. The ITO on or about 18th of August, 1970, assessed the total income to be Rs. 3,53,568. The tax payable was determined at Rs. 2,29,574. The petitioner-company had paid advance tax of Rs. 3,43,160. In the premises, a sum of Rs. 1,13,588 became refundable to the, petitioner. The ITO, accordingly, allowed interest on this sum under Section 214(1) of the I.T. Act, 1961. The assessee, the petitioner herein, preferred an appeal from the order of the assessment. The AAC, on or about 13th December, 1972, allowed in part the appeal. He reduced the total income by Rs. 2,15,915. The AAC directed that assessment be revised by the ITO. On 21st of December, 1972, the ITO passed an order reducing the total assessed income to Rs. 97,229 on the basis of the order of the AAC, The tax payable was thus Rs. 56,228. The ITO, however, did not allow interest on the difference between the advance tax paid and the tax payable according to the revised order. On the 13th of March, 1973, an application was made to the ITO for rectification under Section 154 of the I.T. Act, 1961. On 21st of July, 1973, the rectification application was rejected on the ground that the regular assessment under s, 214(1) of the I.T. Act, 1961, meant assessment under Section 143 of the Act. Thereafter, an appeal was preferred against the order of the ITO to the AAC. The AAC took the same view. An appeal was thereafter preferred from the order of the AAC to the Tribunal. By the order dated 31st of May, 1975, the Tribunal held that this was not a fit case under Section 154 of the I.T. Act, 1961, as there could reasonably be two views possible on the controversy.

3. An application was made, thereafter, under Section 256 of the Act to the Tribunal for referring the question to the High Court. On the 11th of December, 1975, the Tribunal rejected the application on the ground that no question of law was involved. On the 6th of May, 1976, the petitioner moved this court under Article 226 of the Constitution and obtained this rule nisi.

4. In this application, the petitioner is asking, inter alia, that appropriate writ be issued or order made so that the orders passed by the respondent authorities, as mentioned hereinbefore, refusing to pay and/or disallowing interest under Section 214 of the I.T. Act, 1961, on the amount of difference between the advance tax paid and the tax finally determined to be payable for the year 1966-67 may he quashed and/or set aside and justice may be done to the petitioner.

5. The first question, is, whether under Section 214(1) of the I.T. Act, 1961, the claim of the petitioner for interests on the amount of difference between the advance tax paid and the tax finally determined on 21st December, 1972, pursuant to the direction of the AAC is tenable in law. This question was considered by me in the case of Chloride India Ltd. v. CIT : [1977]106ITR38(Cal) . There, for the assessment year 1964-65, the ITO had treated the petitioner as a company in which the public were not substantially interested and charged income-tax on that basis. On appeal, the AAC had held that the petitioner-company was a company in which the public were substantially interested and the petitioner had fulfilled all the conditions laid down in Section 2(18)(b) of the I.T. Act, 1961. Pursuant to the order of the AAC, the ITO revised the assessment and computed the amount refundable to the petitioner at Rs. 4,82,260.40. But the ITO refused to allow interest on the amount under Section 214 of the Act. The assessee filed a revision petition before the Commissioner and he allowed interest tinder s, 244 of the Act, but he disallowed the interest under Section 214 by his finding that the words 'regular assessment' in Section 214 meant the first or original assessment and not the assessment made as a consequence of the order of the AAC. The assessee-company challenged the said finding in the writ petition to this High Court. I held that the obligation under Section 214 of the Act was to pay interest on the amount by which the advance tax paid exceeded the tax determined on regular assessment. An order which was made by the ITO to give effect to the order of the AAC was held by me to be an order of assessment under Section 143 of the Act. If that was the position then in view of Section 214 of the Act the regular assessment, as contemplated by Section 214(1) of the Act, should be the assessment made by the ITO initially or the first assessment made by the ITO if there was no appeal therefrom, but in case there was an appeal the order passed by the ITO finally to give effect to the direction, if any, of the appellate authority. Having regard to the scheme of the Act and the context in which the expression has been used, 'regular assessment.' under Section 214 would include, it was held by me, in the particular facts and circumstances of the case, referred to hereinbefore, to be an assessment made by the ITO pursuant to the direction of the AAC. I had accordingly set aside the order of the Commissioner and directed him to reconsider the matter in accordance with the law. If that is the view then the order passed by the ITO, in the instant case, is erroneous. Counsel for the revenue, however, drew my attention to the decision of the Division Bench of the Allahabad High Court in the case of Laxmipat Singhania v. CIT : [1977]110ITR289(All) , which has considered my decision and was unable to accept the conclusion reached by me, as mentioned hereinbefore. Counsel for the revenue, therefore, asked me to reconsider my previous decision. The Division Bench of the Allahabad High Court, after referring to my decision mentioned hereinbefore, observed that their Lordships were in agreement with me that in Sections 209 and 210 if the expression 'regular assessment' was construed as first assessment certain anomalies, as I had pointed out in my previous decision, would result. But their Lordships of the Allahabad High Court referred to Section 2 of the Act which provided the definition with the words 'unless the context otherwise requires'. According to their Lordships of the Allahabad High Court, if the context of Sections 209 and 210 required, it was permissible to depart from the meaning given to the expression 'regular assesment' in the definition thereof in Section 2(40). But Mr. Justice Chandrasekhar, as the learned Chief Justice then was, observed that such departure should only be for the purpose of these two sections, viz., Sections 209 and 210. According to the learned judge, there was nothing in the context of s, 214 which required that the expression 'regular assessment' not being understood as the first or the original assessment. With respect to the learned judge, it may be observed that, normally, an expression used in a particular chapter should, unless there are other cogent reasons to the contrary, be given the same meaning. The expression used in a catena of sections in a particular Chapter should receive, unless there are good reasons to the contrary, the same interpretation. I should have thought that the proper approach would be to consider whether there is anything in the context of Section 214 which requires giving a different meaning to the expression 'regular assessment' used in that section to the meaning given to that expression as used in Sections 209 and 210 in the same Chapter. It is true that there was nothing in the context of Section 214 which required the expression 'regular assessment' not being understood as the first or the original assessment. But I should have thought that there was nothing also in the context of Section 214 which required that the expression 'regular assessment' be confined to the first or the original assessment. As I have indicated before, the expression 'regular assessment' is of wider amplitude and need not be confined to the first or the original assessment. The legislature has not chosen to use the expression 'first' or 'the original assessment' and, therefore, the expression 'regular assessment' should not be given a meaning different from the meaning which may be attributable to that expression in Sections 209 and 210 and as I have pointed out, in my previous decision, if the expression 'regular assesment' is given the meaning first or the initial assessment in Sections 209 and 210 certain anomalies would result which have also been noticed by the learned judges of the Division Bench of the Allahabad High Court. If an assessment is made by an officer improperly or erroneously will that assessment be more 'regular' than an assessment which is made by the authorities concerned pursuant to an order of the appellate authorities and which remained unchallenged For the reasons aforesaid, I would prefer, with due respect to the learned judges of the Division Bench of the Allahabad High Court, to adhere to my previous view which I have expressed before. This being the position then, as I have mentioned hereinbefore, the order of the ITO is erroneous.

6. Then conies the question whether the petitioner is entitled to any relief in this application. The question will have to be determined in the light of Article 226 of the Constitution, as amended by the 42nd Amendment Act. On behalf of the petitioner, it was contended that even under Article 226 of the Constitution, as amended, this would be entertainable, and the petitioner was entitled to relief because, it was submitted, that the question of enforcement of fundamental rights, as conferred by the provisions of Part III of the Constitution, is involved in this application. It was further urged that deprivation of the right to obtain interest in accordance with law was deprivation of property and, therefore, there was an infringement of fundamental right and if there was any question of infringement of fundamental right, in view of Sub-clause (a) of Clause (1) of the amended Article 226, this petition was maintainable. In this connection reliance was placed on several decisions of the courts. Learned advocate submitted that right to obtain money in the form of interest by virtue of Section 214 of the I. T. Act, 1963, created a certain amount of debt in favour of the asscssee. Therefore, it was submitted that deprivation of that right to the money or that debt amounted to deprivation of property. For the purpose of this application, I will assume that interest that an assessee is entitled to obtain by virtue of Section 214 of the I. T. Act, 1961, is property and if there was an incorrect interpretation of that provision of the law and thereby denial of the right to get any part of that interest then there is deprivation of property. The basic question, however, in my opinion, is whether assuming that there was deprivation of property, in this case can it be said that such deprivation was without any authority of law Learned advocate for the petitioner drew my attention to several decisions. First, he referred to certain cases dealing with the question of pension and placed reliance on the observations of the Punjab High Court in the case of Bhagwant Singh v. Union of India, , where it was held that pension granted to public servant was property attracting Article 31(1) of the Constitution. It was further held in the said decision that the State could not by an executive order curtail or abolish any right of the public servant to receive pension. The said decision of the learned single judge was upheld by the Division Bench and the same is reported in ILR [1965] P&h; 1. The Supreme Court in the case of Madhaorao Phalke v. State of Madhya Pradesh, : [1961]1SCR957 , gives more or less the same view. Again, in the case of Deokinandan Prasad v. State of Bihar : (1971)ILLJ557SC , it was held that the right to receive pension is property under Article 31(1) and by a mere executive order, the State had no power to withhold the same. So far as these cases are concerned, in my opinion, these cases establish the proposition that a claim in the nature of pension is property and denial of right of such property by an executive act without the sanction of any legislation or statute will be deprivation of property without the authority of law. Reliance was also placed on the observations in the decision of the Supreme Court in the case of State of Madhya Pradesh v. Ranojirao Shinde, : [1968]3SCR489 . Then the learned advocate drew my attention to several decisions of the Supreme Court dealing with the cases of assessment under the sales tax law. My attention was drawn to the observations in the case of Stale Trading Corporation of India v. State of Mysore : [1963]3SCR792 , in the case of Coffee Board, Bangalore v. Jt. CTO : [1970]3SCR147 , then to the observation in the case of price fixation and privy purse cases of Madhav Rao Jivaji Rao Scindia v. Union of India, : [1971]3SCR9 , and thereafter to the cases of cash grant, i.e., State of Madhya Pradesh v. Ranojirao Shinde, : [1968]3SCR489 . My attention was further drawn to the observations of the learned judge of the Supreme Court in the case of Additional District Magistrate, Jubalpur v. Shivakant Shukla, : 1976CriLJ945 , in aid of the proposition that though Article 31(1) and Article 21 of the Constitution used slightly different expressions they conveyed the same idea and Article 21 protected the life and personal liberty and deprivation of the same except according to procedure established by law. Similarly, Article 31(1) of the Constitution protects property and states that no person would be deprived of property save by the authority of law. It was urged that the 'authority of law' and 'according to procedure established by law' for this purpose will convey the same meaning. Some of these decisions were considered recently by Mr. Justice T. K. Basu in the case of Nepal Chandra Banerjee v. CTO , wherein the learned judge has considered the observations of the Supreme Court in the cases of Ramjilal v. ITO : [1951]19ITR174(SC) , Smt. Ujjam Bai v. State of U.P., AIR 1962 SC 1621, and also in the case of Coffee Board v. Jt. CTO : [1970]3SCR147 . In the aforesaid decision of Mr. Justice Basu, it was held that where a person was taxed without the authority of law, there was deprivation of his property without the authority of law and, therefore, Article 31(1) of the Constitution was violated and in view of Sub-clause (a) of Clause (1) of Article 226 of the Constitution, the application under Article 226 of the Constitution was maintainable. Reliance was also placed on the decision in the case of Kesoram Industries & Cotton Mills Ltd. v. Union of India, : AIR1977Cal459 . There, a certain company was given certain cash assistance for exports in pursuance of Government circulars and the Government had adjusted it against the other liability alleging that the payment had been wrongly made. It was held that such adjustment would offend the provision of Article 31(1) of the Constitution and affect the company's legal right to property and the application for appropriate writ was maintainable.

7. As I have mentioned before, it is necessary to precisely state the issue involved in this case. In case of illegal taxation the question of acting contrary to the provision of the Constitution would arise because Article 265 of the Constitution provides that no tax would be levied or collected except by the authority of law. Similarly, in the case of privy purse, there is a constitutional guarantee, as was found by the Supreme Court. Other cases of property, be it in the form of cash grant or in the form of pension, cannot be affected or interfered with except by provision of a particular statute or except by the constitutional mandate. I am concerned here with a right which the petitioner claims under the statute. Interest is not a constitutional right. Right to interest is a right flowing from Section 214 of the I.T. Act, 1961. Right to get interest accrues to the petitioner only by virtue of Section 214 of the said Act. That right can be given effect to only by the ITO on his interpretation of the rights of the parties under the section. He is competent to decide this question. If he has the competence to decide it and the jurisdiction to decide it, he has the jurisdiction to decide it right and he has the jurisdiction to decide it wrong. Such a decision of his is amenable to correction by the procedure provided by the I.T. Act which is considered for this purpose to be a code by itself. In such circumstances, denial, because of an erroneous decision of an officer competent to decide the question and his competency and jurisdiction not depending upon the decision that he makes, in my opinion, cannot be said to be denial without the authority of law. If property is interfered with in breach of constitutional mandate, as in the case of taxation or in the case of privy purse or in the case of cash grant or where a property right is interfered with by any executive action without proper legislative sanctions, different considerations will apply. But failure to get the full amount of interest on an interpretation of a legislative provision, by an authority competent to interpret, on which alone the right depends, in my opinion, cannot be said to be the deprivation of property without the authority of law, i.e., not according to the procedure established by law. In this connection reference may be made to the observations of the Supreme Court in the case of Smt. Ujjam Bai v. State of U.P., AIR 1962 SC 1621. In the case of Pioneer Traders v. Chief Controller of Imports & Exports, : 1983(13)ELT1376(SC) , it was held by the majority judgment of the Supreme Court that an order imposing confiscation and penalties under Section 167(8) of the Sea Customs Act, 1878, which was made by a quasi-judicial authority acting with jurisdiction under the said Taxation Act which was intra vires the order was not open to challenge as repugnant to Article 19(1)(f) and (g) on the sole ground that it was based on misconstruction of a provision of the Act inserted therein by a valid order. It was further held that the authority of such an order could not be questioned in a petition under Article 226 of the Constitution. In the case of Coffee Board, Bangalore v. Jt. CTO, : [1970]3SCR147 , it was observed by the Supreme Court that where an action was taken under an ultra vires statute or where although the statute was intra vires, the action was without jurisdiction or the principles of natural justice were violated, a right to move the Supreme Court under Article 32 for enforcement of right existed. Errors of law or fact committed in the exercise of jurisdiction founded on a valid law do not entitle a person to have them corrected by way of petitions under Article 32 of the Constitution. Where there is a process of quasi-judicial determination involved and in that determination, if there is misapplication of the section then only an error within the jurisdiction occurs and deprivation resulting from such an error within the jurisdiction, in my opinion, in respect of a right not flowing from the Constitution but otherwise, would not be deprivation of property without the authority of law. Learned advocate for the petitioner further submitted that if a question of fundamental right was involved, then the further questions whether there was any alternative remedy or it had been exhausted by the petitioner or resort had been made to such alternative remedy were no longer relevant under the amended provisions of Article 226 of the Constitution and for this he drew support from the observations of the Full Bench of the Gujarat High Court in the case of Ahmedabad Cotton Manufacturing Co. v. Union of India, AIR 1977 Guj 113 .

8. For the purpose of this application, in the view I have taken, it is not necessary for me to decide the question whether in a case where the question of fundamental right was involved, before a writ under Article 226 could be issued, it was necessary to consider whether the petitioner had any alternative remedy or whether the petitioner had exhausted such remedy.

9. In my opinion, no question of violation of the fundamental right is concerned in the instant case. Therefore, Sub-clause (a) of Clause (1) of Article 226 of the Constitution cannot be invoked in aid of this application.

10. The next question is if Sub-clause (a) of Clause (1) of Article 226 is not attracted, then whether under Sub-clauses (b) and (c) of Clause (1) of Article 226 of the Constitution the petitioner has any other remedy for the redress of the injury complained of by the petitioner ; because if the petitioner has such other remedy then in view of Clause (3) of Article 226 of the Constitution, as amended, this application is not entertainable. Existence of an alternative remedy before the amendment of Article 226 of the Constitution was not a bar to the exercise of the jurisdiction by the court but was only a factor which the court used to take into consideration in exercising its discretion under Article 226 of the Constitution and in matters of taxation very often the courts adhered to the view expressed and the principles enunciated by the Supreme Court in the case of Shivram Poddar v. ITO : [1964]51ITR823(SC) , wherein the Supreme Court expressed the view that the I.T. Act provided a complete machinery for the assessment of tax and for relief in respect of any improper or erroneous orders made by the revenue authorities. It was for the revenue authorities to ascertain the facts applicable to a particular situation and to grant appropriate relief in the matter of assessment to tax. Resort to the High Court in the exercise of its extraordinary jurisdiction conferred or recognised by the Constitution in matters relating to assessment, levy and collection of income-tax might have been permitted only when the question of infringement of fundamental rights arose or where on undisputed facts the taxing authorities were shown to have assumed jurisdiction which they did not possess. The Supreme Court had further observed that in attempting to bypass the provisions of the I.T. Act by inviting the High Court to decide the questions which were primarily within the jurisdiction of the revenue authorities, the party approaching the court had often to ask the court to make assumptions of facts which remained to be investigated. Therefore, where on undisputed facts it could have been assumed that the order in question was illegal and there was no question of investigation of facts, the court had the jurisdiction and very often did exercise its jurisdiction under Article 226 of the Constitution before the amendment of the said article. More or less the same view was reiterated by the Supreme Court in the case of Champalal Binani v. CIT : [1970]76ITR692(SC) . Reliance may also be placed on Hirday Narain v. ITO : [1970]78ITR26(SC) . But after the amendment it is no longer in the discretion of the court where other remedy for redress of the injury has been provided because no petition under Article 226 for such redress can be entertained in view of Clause (3) of Article 226 of the Constitution.

11. The question, therefore, in the instant case, is, whether there is any other remedy for the redress of the injury complained of by the petitioner. The injury, of which the petitioner is complaining in the instant case, is deprivation of the payment of interest, which according to it, the petitioner is entitled to on a correct interpretation of Section 214 of the I.T. Act, 1961. Section 214 of the I.T. Act, 1961, as such does not contemplate making of any order. It gives the assessee a right to interest under conditions and in the circumstances mentioned in the section. How those rights can be enforced, the Act as such is not explicit but it must be presumed that in normal course the ITO would pass an order or give a direction to the effect or in consonance with the provisions of Section 214 of the I.T. Act, 1961. In the instant case, the ITO has done that as early as 23rd December, 1972. This order is not appealable. This order can, however, be the subject-matter of a revision application by the petitioner within the period of one year from the date of the communication to the petitioner of the order under Section 214 of the I.T. Act, 1961. The petitioner did not apply for revision. Strictly speaking, this was a remedy for the redress of the injury that the petitioner is complaining. The petitioner, on the other hand, applied for rectification of what the petitioner considered to be an error apparent from the record under Section 154 of the I.T. Act, 1961. The said application was rejected. There was an appeal to the AAC from the said decision of the ITO and thereafter there was an appeal to the Tribunal which held that there was no question of an error apparent from the record. The Tribunal accordingly rejected the petitioner's appeal. The petitioner sought certain questions to be raised for reference to the High Court. Such application has also been refused. The petitioner thereafter did not pursue the other course for applying to the High Court for directing a reference of the question of law involved. It was submitted on behalf of the petitioner that the remedy either by application for revision under Section 264 of the I.T. Act, 1961, or by moving the High Court for directing the Tribunal to make a reference on questions of law could not be direct remedy for the injury complained of and for this submission reliance was placed on the observations of the Full Bench of the Gujarat High Court in the case of Ahmedabad Cotton ., : AIR1977AP250 [FB]. There, of course, the court held that the Industrial Disputes Act had provided a clear remedy for adjudication of the disputes by the labour courts and the industrial tribunals once a dispute was raised and the same has been referred to them. The court, however, was of the view that the 'other remedy' contained in Clause (3) of Article 226 of the Constitution must be capable of affording such redress as was postulated under Sub-clauses (b) and (c) of Clause (1) of Article 226 and the words 'any other remedy for such redress' were significant and meaningful and they clearly brought out the intention of Parliament that only that other remedy which was truly and really capable of giving such redress as was postulated in Sub-clauses (b) and (c) of Clause (1) of Article 226 of the Constitution would be a bar to the maintainability of the writ petition. It was, however, impossible to lay down any hard and fast rule. It is true that the other remedy must quantitatively and qualitatively give the same relief to the injury complained of before the bar under Clause (3) could be attracted in respect of any illegal or improper order to oust the jurisdiction of the court under Article 226 of the Constitution. But such other remedy for the redress need not result in the immediate redress nor such remedy need provide for direct redress. That would, in my opinion, be reading into the Constitution some other expression not provided for therein. It is true that if the redress to the injury provided by other statutes or other provisions is too remote or too circuitous then the remedy may not be an effective remedy or may not be a remedy as contemplated. But so long as qualitatively and quantitatively the remedy affords the same redress to the injury of the petitioner, then such redress obtained not directly but by going through a process, in my opinion, would not take away such remedy from the purview of Clause (3) of Article 226 of the Constitution. If that is the position, then in view of the provisions of the I.T. Act as mentioned hereinbefore, the petitioner had other remedies for the redress of the injury complained of by the petitioner and that being the position, in my opinion, the application under Article 226 of the Constitution, in view of Clause (3) of the said article, cannot be entertained and in this matter this court has no discretion and the cases or the principles which controlled the discretion of the court prior to the amendment of Article 226 of the Constitution would not be applicable.

12. Another contention was raised on behalf of the respondent that the application was belated. It was submitted that the order of the Tribunal refusing to make an order of reference was passed on the 17th December, 1975, and the instant application has been moved on the 6th May, 1977. It was urged that there was no explanation for the delay of about 1 1/2 years. If this application was entertainable 'then of course the question of delay might have been a factor to be taken into consideration in granting relief under Article 226 of the Constitution and then the question might have arisen whether having entertained this application it would be proper to refuse such an application on the ground of delay. It was further submitted that there was some explanation for the delay in the sense that in view of the previous decisions of the Bombay High Court and the Allahabad High Court and there being no decision of the Calcutta High Court exactly on the point, the petitioner had reason not to pursue furtheruntil the decision in Chloride India's case : [1977]106ITR38(Cal) , of thiscourt, was published. As I said before, this, question would only arise inexercising the court's discretion in granting relief had this applicationbeen entertainable. But in the view I have taken before, under Clause (3) of Article 326 of theConstitution, this application is not maintainable and, therefore, mustfail. The rule nisi is accordingly discharged. In the facts and circumstances of this case, there will be no order as to costs. Interim orders, ifany, are vacated.


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