As per case facts, the appeals challenged the validity and interpretation of provisions within the Calcutta Municipal Corporation Act 1980, specifically Part 4 Chapter 12, concerning powers of taxation and ... fixation of consolidated rates. Petitioners, including tenants and landlords, argued that certain provisions regarding assessment, apportionment, recovery, and the right to appeal were unworkable, impractical, and unconstitutional. They contended that the system disproportionately burdened tenants with tax, especially the surcharge, and denied them proper participation in the valuation process and an effective right to appeal without depositing the full tax amount. The question arose whether the impugned provisions of the Act, particularly sections relating to valuation, apportionment of tax burden between owners and occupiers, recovery mechanisms, and the pre-condition for appeal, were legally sound and provided adequate safeguards for all affected parties. Finally, the Supreme Court upheld the High Court's judgment with clarifications, affirming that tenants, sub-tenants, and occupiers, as 'persons liable', have a right to participate in the assessment process through public and written notices, submit returns, and raise objections. It clarified that they also have a right to appeal against the consolidated rate or surcharge upon depositing only their apportioned share of tax, not the entire building's tax. The Court emphasized the rule of 'reading down' to interpret provisions harmoniously and ensure workability, stating that non-issuance of notices would not invalidate proceedings unless serious prejudice is proven. It also affirmed the legal fiction treating tax as 'rent' for recovery purposes and found no discriminatory treatment among tenants regarding the Tenancy Act.