There was no agency relationship between the appellant and respondent as the respondent collected the levy as a public body on behalf of the government, not as agent for the appellant. The cashewnut export levy was not a tax as it was not enacted by tax legislation or government order, and the respondent had no statutory power to impose or remit the levy to the appellant. The appellant was merely a beneficiary, not a principal, and thus not entitled to claim the sum as money had and received or for conversion.
There was no agency relationship between the appellant and respondent as the respondent collected the levy as a public body on behalf of the government, not as agent of the appellant. The cashewnut export levy was not a tax as it was not enacted by tax legislation or government order. The respondent was not liable to remit the claimed sum to the appellant.