Switz v. Township of Middletown

*618Vanderbilt, C. J.

(dissenting).

I.

Background

By 1875 the unfairness of taxation in Few Jersey had reached the point that a constitutional amendment was passed by two successive Legislatures and adopted by the people “at a special election to be held for that purpose only * * * by a majority of the electors qualified to vole for members of the legislature voting thereon.” The amending process under the former Constitution of 1844 was indeed difficult of accomplishment, Const., Art. IX, but the need for relief from inequitable taxation was deemed overwhelming. The amendment was simple and seemingly unambiguous:

“Property shall be assessed for taxes under general laws, and by uniform rules, according to its true value.” (Art. IV, See. VII, par. 12, as amended, effective September 28, 1875; all italics supplied)

All the statutes passed pursuant thereto as well as under the corresponding provision of the Constitution of 1947 (to which I shall refer in due course) have uniformly adhered at every level of the taxing machinery — municipal, county and state — to the standard of true value ordained by the Constitution of 1844. These statutes are still the governing law of Few Jersey, N. J. 8. A. 54:4-1 at the local level; B. 8. 54:3-13 and N. J. 8. A. 54:1^47 at the county level; and N. J. S. A. 54:2-39 at the state level. It is difficult to conceive of a standard of assessment for taxation more simple or more fair than the standard of assessment at true value.

Yet from 1875 until the present day the very obvious will of the people has been frustrated, notwithstanding the fact that the great increase of government expenditures in the present era of large governmental operations has entailed vast increases in taxation. This unfortunate breakdown in the enforcement of the 1875 amendment has been due, first, *619to the narrow judicial construction as to the right of a taxpayer to avail himself of the clear popular mandate for taxation at true value, Royal Mfg. Co. v. Board of Equalization of Taxes, 76 N. J. L. 402 (Sup. Ct. 1908), affirmed 78 N. J. L. 337 (E. & A. 1909); second, to the complicated and ineffective taxing machinery at the local, county and state levels; third, to the long-continued failure of the municipal assessors throughout the State to comply with the Constitution of 1844 and the controlling statutes; and fourth, to the failure of the county taxing authorities to supervise the work of the local assessors except through the mechanical equalization of aggregates within a county which reaches only a small part of the widespread and almost universal inequities in the administration of the tax law. Whatever hope there was of obtaining compliance by the local tax assessors of their statutory obligation to assess at true value was diminished when the Legislature as late as December 19, 1955, L. 1955, c. 244, repealed N. J. S. A. 54:L-36 requiring each assessor to annex to his assessment list an affidavit stating among other things:

“I, « * * do swear (or affirm) that the foregoing list contains the valuations made by me to the best of my ability, of all the property liable to taxation in the taxing district in which I am the assessor, and that I have valued it, without favor or partiality, at its full and fair value, at such price as in my judgment it would sell for at a fair and bona fide sale by private contract on October first last * *

The local assessors are politically elected or appointed officials, many of them part-time workers, incapable of doing the work of taxing experts. Most of the county boards of taxation are not properly financed to do the work the statutes require of them. Only at the state level has the Director of the Division of Taxation attempted to ascertain true value by the systematic assembling of sales data, primarily for the purpose of apportioning state aid to schools, but incidentally for the benefit of the county boards of taxation in their mechanical equalization of assessments in the various municipalities of each county. To understand the present *620deplorable state of affairs the decision in the crucial case of Royal Mfg. Go., above referred to, must be understood, because it is to a large extent the cause of our present difficulties. There it was held that a taxpayer whose property is not assessed at more than true value has no standing to complain, because under the 1875 amendment to the former Constitution all property must be assessed at true value, and that even if he was discriminated against in favor of other taxpayers, he could not have his assessment reduced, but rather must seek to raise the assessments that were lower than his. This legalistic decision placed on the individual taxpayer the intolerable burden of proving the true value of each property in the municipality — a burden which he could not possibly hope to meet by reason of the sheer expense of such a suit. This unfortunate decision not only ignored the realities of the taxing process; it ushered in the era of what the public and the press, when its possibilities came to be understood, quite properly called “tax lightning.” The Commission on State Tax Policy euphemistically but graphically expressed the existing situation in its Fifth Report (1950; p. 4) :

“The administration of the general property tax (real estate and improvements) is a chaos. On the business side it is a matter of a more or less gentle bargaining process that over the years has created a host of insecure but ‘favorable’ conditions.”

This statement is documented with complete county by county tables in its Sixth Report (1953; p. 30). At page 27 the Commission summarized its findings as follows:

“Real estate in New Jersey is assessed at an average assessment ratio of 34 per cent of its value. On this basis, the State-wide average tax rate of $6.77 per $100 valuation taxable in 1952 represents an average effective tax burden of $2.30 per $100 of full value.
The estimated average assessment ratios vary as among the 21 New Jersey counties from a low of 16 per cent in Ocean County to a high of 56 per cent in Hudson County. Six of the State’s 21 counties show estimated average assessment ratios above the overall State-wide average of 34 per cent and three of them (Hudson, *621Essex and Passaic) show estimated average assessment ratios above 40 per cent. On the other extreme, four counties (Ocean, Burlington, Sussex and Salem) show estimated average assessment ratios of under 20 per cent.
The variation as among individual municipalities ranges from estimated average assessment ratios under 10 per cent in seven municipalities to over 00 per cent in two municipalities.”

Its conclusion (p. 133) as to the inequities of taxation throughout the State seems inescapable:

“Never has so much money been raised from so many people so inequitably as in the current administration of the local tax on real estate."

Here we have conclusions of fact documented by years of competent study by an official commission that we cannot afford to ignore in the consideration of such vital issues.

The only relief that has been accorded aggrieved taxpayers in Few Jersey has come, not through the 1875 amendment, but by virtue of the equal protection clause of the Federal Constitution in the Hillsborough Township, Somerset County, N. J. v. Cromwell case, 326 U. S. 620, 66 S. Ct. 445, 90 L. Ed. 358 (1946), in which the inadequacy of the Royal Mfg. Co. case was adversely commented upon by the United States Supreme Court. In this case the tax collector of a small Few Jersey community with total assessed valuations for all property, both real and personal, of $3,139,020, levied assessments in the amount of $221,940,438 upon the intangible property belonging to an individual resident and to a trust of which she was trustee. This assessment would have resulted in additional tax payments of nearly $7,000,000 per year as compared with the township’s annual budget of approximately $97,000, an outrageous instance of “tax lightning” which had become prevalent in various parts of the State. In that case the United States Supreme Court, which seemed more aware of the economic and political realities of taxation than our courts at that time, correctly criticized the Royal Mfg. Co. decision for failing to accord the taxpayer the protection to which he was entitled under the Federal Constitution:

*622“The equal protection clause of the Fourteenth Amendment protects the individual from state action which selects him out for discriminatory treatment by subjecting him to taxes not imposed on others of the same class. The right is the right to equal treatment. He may not complain if equality is achieved by increasing the same taxes of other members of the class to the level of his own. The constitutional requirement, however, is not satisfied if a State does not itself remove the discrimination, but imposes on him against whom the discrimination has been directed the burden of seeking an upward revision of the taxes of other members of the class. Sioux City Bridge Co. v. Dakota, County, 260 U. S. 441, 445-447, 43 S. Ct. 190, 191, 192, 67 L. Ed. 340 * * *; Iowa Des Moines Nat’l Bank v. Bennett, 284 U. S. 239, 247, 52 S. Ct. 133, 136, 76 L. Ed. 265; Cumberland Coal Co. v. Board of Revision [of Tax Assessments], 284 U. S. 23, 28, 29, 52 S. Ct. 48, 76 L. Ed. 146. The courts of New Jersey in a long line of decisions have held that a taxpayer who has been singled out for discriminatory taxation may not obtain equalization by reduction of his own assessment. 1-Iis remedy is restricted to proceedings against other members of his class for the purpose of having their taxes increased. The rule was stated in Royal Mfg. Co. v. Board of Equalization [of Taxes], 76 N. J. L. 402, affirmed in 78 N. J. L. 337, as follows: * * the county boards are required to secure taxation of all property at its true value; so that the fact that the property of A is assessed at its true value, and the property of other taxpayers within the same district is assessed below its true value, affords A no ground for demanding a reduction of his valuation, though it does entitle him to apply for an increase in the valuation of the others.’ 76 N. J. L., at pages 404, 405. On the basis of that rule it is plain that the state remedy is not adequate to protect respondent’s rights under the federal Constitution.” (326 U. S., at pages 623-624, 66 S. Ct., at page 448.)

Had our courts applied the same reasoning and the same requirements of proof in the Royal case, the 1875 amendment and the implementing statute would have been quickly complied with by the taxing authorities.

The doctrine of the Royal case was not put to rest in this State until the decision of this court in Baldwin Construction Co. v. Essex County Board of Taxation, 16 N. J. 329 (1954); see Gibraltar Corrugated Paper Co. v. North Bergen Township, 20 N. J. 213 (1955), at page 219. Meanwhile the evil of unfair taxation multiplied. There is inequity among the municipalities of a county, only partially overcome by the equalization of aggregates; there is inequity in many municipalities among different types of property; and there *623is~the greatest of inequity among individual taxpayers owning the same type of property within a municipality, neither of which evils is reached by the equalization method.

In these days of bulging taxes at all levels, the matter of taxation naturally came before the Constitutional Convention of 1947, which labored with the problem, deleted all reference to taxation at true value, and came forth with a new expression of tax policy:

“Property shall be assessed for taxation under general laws and by uniform rules. All real property assessed and taxed locally or by the State for allotment and payment to taxing districts shall be assessed according to the same standard of value; and such real property shall be taxed at the general tax rate of the taxing district in which the property is situated, for the use of such taxing district.” (Const. 1947, Art. VIII, See. I, par. 1)

Over nine years have passed since the adoption of the new Constitution, but the new provision has not been availed of by the Legislature. The taxation statutes still call for assessments at true value, N. J. S. A. 54:L-1, R. S. 54:3-13, N. J. S. A. 54:L-47 and N. J. S. A. 54:2-39, supra, but the violations of these statutes are just as universal and rampant as they ever have been. The Legislature has never attempted to utilize the constitutional provision of 1947, above quoted, but on the contrary submitted a proposed constitutional amendment to the people last year (1956) on the subject of taxation which would have added to the present Art. VIII, Sec. I, par. 1 the following sentence:

“The Legislature may authorize the governing body of any municipality constituting a taxing district to establish a proportion of the standard of value at which such real property situate therein shall be assessed, and such proportion shall be uniformly applied to all such real property within the taxing district.” Assembly Concurrent Resolution No. 36. Filed July 17, 1956.

In a release dated November 2, 1956, the New Jersey Commission on State Tax Policy opposed the adoption of such an amendment saying:

“ACK.,36 is intended to head off the effects of an anticipated decision of the State Supreme Court affirming the appellate division *624decision in Switz v. Middletown Township. That decision requires assessors to follow the existing law by valuing property at 100 per cent of true value. If the Legislature considers a lower percentage appropriate it has only to amend the statutes, not the Constitution.”
“* * * the Commission would emphasize that it would be a mistake, from the viewpoint of the long range development of a sound tax system in New Jersey for the people to approve the amendment of the Constitution proposed by ACR 36. All of the proper objectives of this proposal can be accomplished by legislation. The amendment of the Constitution, on the other hand, would create vested interests in the bad practices of the past. The proposal has little merit beyond an easy and temporary method of avoiding statewide equalization on full value assessments, and can result in nothing more than an extension of the past century of inequities.”

This proposed amendment was rejected by the people at the polls, Minutes of the Board of State Canvassers, Department of State, December 4, 1956, page 7, some claiming that it meant one thing and would produce one result, and others claiming that it meant quite another and would produce a different result. Clarity is the great prerequisite of any tax law, and in this State in view of our experience under the 1875 amendment that clarity must be such that the courts cannot misunderstand or misconstrue; see 2 Sutherland Statutory Construction (3d ed.), page 334, where the author observes:

“It is not allowable to interpret what has no need of interpretation.”

The mounting pressure of taxation has led to a renewal of litigation to achieve assessment at true value, where heretofore procedural reasons have been advanced to deny relief; see Baldwin Construction Co. v. Essex County Board of Taxation, supra, 16 N. J. 329 (1954), where the court held that it was bound by the nature of the proceeding brought which sought only to review the action of the tax board and refused to give effect to the requirement of true value because to do so would result in relief in the nature of mandamus bearing on the future performance of statutory functions *625that had not been sought by the pleaded cause; see also Gibraltar Corrugated Paper Co. v. North Bergen Township, 20 N. J. 213 (1955), where the court at the behest of the complaining taxpayer reduced the taxes from true value to the level set by the standard used in assessing other properties in the municipality. The difference between that case and the instant case is that here the taxpayer is asking to have the property taxed at true value pursuant to the statute.

II.

The Pending Case

Now for the first time we are confronted with a simple suit by a taxpayer of a municipality directly attacking the assessments in the municipality as being at less than true value and seeking to remedy discriminatory and unfair taxation resulting therefrom by forcing general compliance with the command of the statute to assess at true value. The case has gone through the Law Division of the Superior Court and the Appellate Division of that court. Meantime the defendant municipality has undertaken a reappraisal according to true value of all of the property within the municipality, and we have been advised that that reappraisal has now been completed.

Thus, the case as between the plaintiff-taxpayer and the defendant-municipality and its tax collector is now ripe for decision. To delay decision in the instant ease and to permit the inequities of taxation that have existed in the Township of Middletown to continue because some other municipalities have refused to see the handwriting on the wall, as the majority and concurring opinions do, cannot be justified. . Incidentally, we are told in the majority opinion that 99 municipalities have undertaken professional revaluation programs in anticipation of enforcement of assessments at true value and 15 more are contemplating such action, but such proceedings, either undertaken or contemplated, constitute no reason for withholding action in favor of the aggrieved taxpayers of the Township of Middletown while we are awaiting either revaluation programs in the remaining municipalities of this State, *626or a new taxation program from the Legislature. The decision of this case in favor of the plaintiff does not bind any other municipality in the State, though it would, of course, serve notice as to the necessity of their complying with this statute directing assessment of property at true value.

The majority of the court fear that a decision in favor of the plaintiff, effective now, would upset the economy of the State. To my mind this is attributing to a judgment in favor of the plaintiff, effective now, after a revaluation has been completed in the township, a fanciful result, which in the meantime deprives the plaintiff and other similarly situated taxpayers of their undeniable right to immediate fair treatment. The situation in every other municipality would still require decision on the basis of the facts of its particular case, if i.t comes before the courts.

The majority and concurring opinions concede that in principle the plaintiff is entitled to relief and they acknowledge that conformity with' the statutory plan is much to be preferred over the present state of affairs. Yet, because none of our 567 municipalities (except Princeton Township alone) assess at true value at the present time and because of their “fears,” they have elected to excuse non-compliance with the law by the defendants and thus compound the pernicious effects of disregard of the statute. They are afraid that any sudden and drastic change in the established practice could work detriment to the economic and community fiscal aspects of life in this State; that in the areas where it is said “industries were lured by gentlemanly understandings of tax preference,” forced equality of treatment may result in the chasing away of the industry and the imposition of the burden borne by it upon the residential property, principally the small home owner; that there will be the temptation, in anticipation of increased revenues, to yield to the desire to obtain those things which have been thought necessary but heretofore unobtainable because of the lack of the wherewithal to purchase them; that a rapid unconsidered transition from failure to comply with the law to compliance *627with the law will create new conditions not “conducive to common and individual right”; that to order fulfillment of the statutory mandate in but one municipality is to increase the inequities that already exist; that the resulting increase in the debt limitations caused by sudden increases in the aggregate valuations will “lead to pressures to borrow more” and that the measures adopted to alleviate these conditions may result in even greater problems.

' There is nothing in the record or in the facts before us to justify these fears of the majority, once the court realizes (1) that the decision of this case concerns only Middletown Township and its inhabitants, and (3) that if any other municipality has some special equity that Middletown Township does not have as to the time when its assessments shall be made at true value, it may assert its peculiar equity when its case comes on for hearing. Any peculiar situations in other municipalities are not at all related to the problems of Middletown Township and cannot be permitted to interfere with the decision in its ease. The Township of Middletown has undertaken the reappraisal of all of the property within its borders at true value pursuant to the governing statutes. Without any outside help it has completed all but 35% of the reappraisals and under legal advice is prepared to apply a formula to the balance of the properties to bring those appraisals to an estimated level of true value and thus be in a position to comply forthwith with any judgment of this court requiring immediate assessment at true value. It is, however, now awaiting the judgment of this court before actually assessing all of the property in the township. Meantime, the township has not filed its assessments with the Monmouth County Board of Taxation, although we have been assured that they are in a position to do so forthwith, with the result that the County Board of Taxation has been unable to strike a county tax rate or to readjust the aggregate ratables among the municipalities in the county based on the actual assessments for the Township of Middletown. The failureljof this court to decide in the pending case to order immediate compliance with the statutory standard is thus *628not only interfering -with the orderly course of taxation in the Township of Middletown bnt throughout the county as well. The instant case is obviously ripe for decision.

The majority are concerned with an imaginary possibility that in the year of transition from the old order to the new system of assessments at true value more taxes may be raised than were provided for in the budget of the municipality. But there can be no windfall to the governing body of the municipality at the expense of its taxpayers. The present statutes safeguard the citizens against such a contingency. The Local Budget Law, R. S. 40:2 — 1 el seq. requires that every municipality adopt a budget for each fiscal year, R. 8. 40 :2 — 5, and to state in it the “amount to be raised by taxes,” R. 8. 40:2-13 and 15. This budget upon adoption constitutes “an authorization of the amount to be raised by taxation for the purposes of * * * the municipality,” R. 8. 40 :2 — 11. The grant of power by the Legislature “to assess, levy and collect taxes” is granted solely for the purpose of supporting “any budget adopted” pursuant to statute “and for all other lawful purposes,” R. 8. 40:2-19; see also 40:48-7. Once the budget is adopted, R. 8. 40:2 — 8, the amount required for public purposes in a particular year has been determined, and except in extraordinary cases it cannot be altered, R. 8. 40 :2-8, supra, R. 8. 40:2-9, 40 :2-20. The intent of the law is that the receipts, including taxes, in that year should equal the authorized appropriations of the budget. The scheme provided for by statute is that the amount of money required for the public purposes of the municipality be first proposed and fixed and determined after a public hearing, at which the people affected have an opportunity to voice their opinions, R. 8. 40 :2-6; that the tax rate then be computed by dividing the amount called for by the budget by the gross or aggregate value of the assessments. Thus, the total amount of ratables of a municipality for the particular year in question, multiplied by the tax rate, should equal the amount authorized for public purposes by the budget, R. 8. 54:4-48. If the assessment of properties in a municipality at true value is completed *629and approved prior to the adoption of the budget, as in the usual course it would be, R. S. 54:4-42, R. 8. 40:2-10, the new tax rate will reflect the change caused by assessment at true value, R. S. 54:4-48, supra. If, however, an increase in the gross value of the ratables in a municipality is caused by assessments at true value after the tax rate is fixed and determined for a particular year based on less than true value assessments, the amount of taxes that would actually be raised would be grossly disproportionate to the amount required by the adopted budget to be raised by taxation and therefore unauthorized.

Protection against any undue inflation of the borrowing power of a municipality is already given by the provisions of the Local Bond Law, L. 1935, c. 77, where the debt limit provided for is based upon the average of “the three next preceding assessed valuations of taxable real property” of a municipality, R. 8. 40:1-15 and 16, R. 8. 40:1 — 80 and 82. This would give the Legislature until the session of 1958 to adjust the statutory debt limits, if any adjustment is necessary. As to the years following the year of transition, the taxpayers have it within their power to voice their opinions to their elected representatives as to how much municipalities should spend. The real interest of the taxpayers is in the number of dollars they will be called upon to pay in taxes rather than in the rate at which they are to be taxed and as to the future, as it does today, public opinion and law will protect the people from unconscionable burdens. ^

III.

Procedure

The majority opinion goes into an elaborate review of the law of the former remedy of mandamus and seeks to justify its position with the theme that mandamus will be refused when it would promote a wrong rather than redress one, where “the result will be ‘disorder and confusion,’ ” when it would “work a public injury or embarrassment” and where it would “coerce an act which will work a public *630or private mischief.” But none of the cases or authorities relied upon state any principles that would serve to prevent the immediate granting of the relief sought by the plaintiff here. The duty sought to be enforced — the assessment of all property at true value according to the statutory command — is a peremptory one and meets the test of being “so plain in point of law and so clear in matter of fact that no element of discretion is left as to the precise mode” of performance set forth by the authorities cited by the majority. Mandamus, along with the other prerogative writs, was superseded by the 1947 Constitution, Art. VI, Sec. Y, par. 4, and in lieu thereof relief as of right has been afforded in civil cases by action in the Superior Court, B. B. 4:88. This provision of the Constitution not only swept aside the discretionary allowance of these prerogative writs and made them proceedings of right, but it was also designed to abolish the many technical requirements and limitations on the use of these prerogative writs and to substitute in their place a proceeding based on equitable principles adapted to the needs of each particular case. The neat distinctions between the several former prerogative writs have no more meaning today than the distinctions that once existed between trover and trespass among the •forms of action of an earlier day, or between bills of inter-pleader and bills in the nature of a bill of interpleader among the equitable remedies of yesterday. These matters are no mere formalities. They go to the very heart of an adequate remedy. The former prerogative writs, like the former forms of action, were encumbered by many technical limitations as distinguished from equitable proceedings which developed later in the story of law and were governed by principles far more flexible and adaptable to individual cases. It is quite as important to the usefulness of proceedings in lieu of prerogative writs that they proceed on equitable principles and be governed by the flexibility of equitable rules as it is that they issue as of right free from the former restrictions of judicial interventions. As was said in Ward v. Keenan, 3 N. J. 298, 308-309 (1949):

*631“Our problem is, therefore, by rules of court and judicial decisions, to preserve as far as may be the substantive law of the former prerogative writs as a means of safeguarding individual rights against public officials and governmental bodies, while at the same time avoiding the defects of procedure that led to criticism. * * *
In determining what course to pursue under the new practice in this field we should look to the decisions on the old procedure on prerogative writs, not as controlling authorities but for what light they may throw on the instant problem of presenting sound rules of procedure. Much light may also be gained from examining the practice in analogous cases of equitable procedure, for it is becoming increasingly clear, now that discretion in granting of the writ has been abolished, that the procedural principles applicable in the two fields are in many respects identical.”

Such actions, although administered in the Law Division of the Superior Court because their predecessor writs originated there, concededly proceed on equitable principles which are as much within the power of the Law Division to apply as it is for the Chancery Division to apply the principles of common law. To hold otherwise would be to unduly restrict, and without serving any purpose whatsoever, the usefulness of proceedings in lieu of prerogative writ.

Here the power of the court to impose, if necessary, restrictions on the amount of tax funds that may be raised under this judgment in the period of transition, is clear. The power of equity to prevent accident and mistake is fundamental. It took so long to free proceedings in lieu of prerogative writ from the technicalities of the former prerogative writs that any return to this outmoded learning would be deprecated.

IV.

Conclusion

The majority says the “dominant principle of the new constitutional mandate is equality of treatment and burden” and that the standard of true value, “the peremptory statutory assessment criterion,” is “but a means of realizing uniformity and equality.” But the new constitutional mandate has not yet been implemented by the Legislature and *632we have no way of knowing whether or not it ever will be. The attempt to amend the Constitution of last year certainly does not lead us to any conviction that the Legislature is intending the adoption of any statutes implementing the taxing provision of the 1947 Constitution. We are merely called upon to enforce the statutory standard of assessment at true value. That being so, how can a determination of the matter before us which in itself ignores that “peremptory statutory assessment criterion” of true value and suspends for two — or according to the concurring opinion three — tax years the application of the principle of equality of treatment and burden and delays the assessment of property at true value, be said to be the one demanded by the equities of the case?

Professor James C. Bonbright, of Columbia University, in his work “The Valuation of Property ” volume I, pages 497, 498, says:

“Theoretically the taxpayer’s pocket is not in the least affected by uniform undervaluation or overvaluation. Systematic undervaluation diminishes the tax base, and the rate must therefore rise in order to supply the required government revenue. * * * The objections to the practice of undervaluation are patent. In the first place, except where sanctioned by statute, it involves a generally known and sanctioned disregard by officials of the law requiring them to assess property at its full and fair value. The other great vice is that the percentage of undervaluation is rarely a matter of common knowledge, so that it is extremely difficult to ascertain whether there is uniformity in the proportion or whether, through incompetence, favoritism, or corruption of the assessors, some portions of the taxing body are bearing the others’ burdens, as between either individuals or local groups.”

Equity will never condone disrespect for the law, for equity follows the law. Equality of treatment and burden is equity; to delay equity is to deny equity.

The majority opinion calls for delaying compliance with the mandate of the statutes until the tax year 1959 so as to afford “the Legislature the opportunity to take such measures and provide for such administrative procedures as its own inquiry may prove to be essential to the public interest, and to allow the Township time needed for the *633fulfillment of the project.” This court has no right to withhold judgment on statutes which date back to 1875 to give “the Legislature the opportunity to take such measures and provide for such administrative procedures as its own inquiry may prove to be essential to the public interest, and to allow the Township time needed for the fulfillment of the project” at the expense of the plaintiff and other similarly situated taxpayers. The township, on the other hand, does not need and does not ask for time for “its project.” Its reassessment is finished; the time for decision has arrived.

The concurring opinion would give our citizens a “decent opportunity to seek an orderly solution * * * through their elected representatives or by constitutional amendment.” But the problem is not a new one. It has long been with us. In one phase or another it has been before this Court for years, beginning with the Baldwin case in 1954. Without legislative direction over a hundred municipalities have undertaken a program looking forward to the carrying out of the mandate of the statutes, but they have never given a hint that they intend to comply with the law voluntarily. On the contrary, after arriving at true value they have, with the exception of Princeton Township, arbitrarily fixed a percentage of true value for assessment purposes. The courts have given adequate notice of the requirements of the law and have pointed out the wholesale disregard of it, and still compliance has lagged. In spite of all of this the Legislature has not changed the law, if indeed changes can be made which will improve the laws based on the sound principle of assessment at true value. We must, therefore, apply the law as we find it and not indulge in excuses not even presented to us.

The question before us is whether we will recognize the clear and unmistakable mandate of the statutes for assessment at true value and direct performance of the solemn duty of the defendants to assess at true value or ignore it and make ourselves a party to the positive disregard of the statutes. Any such weakness on the part of the court in *634enforcing what is clearly the law can lead only to disrespect of its judgment. On the other hand, by insisting on adherence to the standard of true value, we effectuate the purpose and policy of the existing law, extinguish the evils that have grown up from the acceptance of a percentage of true value as an adequate standard of value and make policing of abuses infinitely easier, in the interest of realizing equality of treatment and burden.

Li would affirm the judgment below for the reasons expressed herein.

Mr. Justice Jacobs has authorized me to say that he joins me in this dissent.7