Emmanuel v. The Commissioner-General of Inland Revenue – sllr 1990 volume 1 page 209
In the case between Emmanuel (Plaintiff) and the Commissioner-General of Inland Revenue (Defendant), the court addressed the issue of whether the learned Additional District Judge was justified in altering a previously ordered instalment payment schedule in the absence of an application by the Commissioner-General or evidence of any changed circumstances. It was held that the order enhancing the instalment from Rs. 3,000 to Rs. 10,000 per month was erroneous and without jurisdiction, reaffirming the principle that judicial orders concerning payment instalments must be based on formal application or proven change of circumstances. This decision relied on procedural fairness and established judicial practice, emphasizing that modifications to payment orders require appropriate legal grounds

