Whether issue of notice to municipal corporation prior to filing of suit against it is mandatory in all the cases?

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The High Court of Bombay headed by Justice A.S. Chandurkar in Shri. Gorakshan Sanstha v. The Akola Municipal Corporation, 2019 (1) MHLJ 776, observed that as per provisions of Section 487 of the said Act a protection is granted with regard to any act done or purported to be done in pursuance or in execution or intended execution of the said Act. In that regard unless a notice is given by the plaintiff with duration of one month and a suit filed within six months of the accrual of the cause of action, such suit cannot be instituted. Having found that the plaintiff Trust was entitled for exemption under Section 132(1)(b) of the said Act it was clear that the Trust was not liable to be assessed for payment of tax. If that be the situation then issuance of the demand notice on 04/01/2011 cannot be said to be an act done in pursuance of or in execution of the provisions of the said Act. 
In other words there being an exemption from payment of taxes under Section 132(1)(b) of the said Act, there would be no cause to demand such taxes by issuing any demand notice. Moreover, the said demand notice has been held to be illegal. It is thus clear that the demand notice was issued despite the fact that the plaintiff was exempted from payment of taxes. In such situation it will have to be held that the suit was not liable to be dismissed for failure to issue notice under Section 487 of the said Act as present case such notice was not required to be issued.