The collector of taxes was accused in court yesterday of behaving like a Qing dynasty ruler who beat citizens on the buttocks 30 times before allowing them access to the courts. Gerard McCoy QC said the same principle applied to tax laws which left flat buyers unable to appeal against an inflated demand for stamp duty unless they paid up first. 'In the Qing dynasty, before you could go to see a judge you had to be beaten 30 times on the buttocks. We say that is exactly what is happening with stamp duty,' he said. Stamp duty laws breached human rights by providing one law for the rich and another for the poor, Mr McCoy said. The unhappy taxpayer could not go to the appeal court unless he could afford to pay the disputed sum. Mr McCoy is representing Chan Siu-chen who claims she is being asked to pay stamp duty twice on the same property. The name of her company, Harvest Sheen Limited, was left off the provisional agreement for buying a luxury $12.3 million villa in Hong Lok Yuen, the court heard. The administrative error led to the document being sent back by the Inland Revenue Department. It was altered and returned, but the $338,250 stamp duty was charged twice, once for each time the document had been tendered. Mr McCoy described the decision as 'perverse'. But if Ms Chan wants to appeal against it she must pay the full sum of $676,500 before her case can go to the District Court. This part of the Stamp Duty Ordinance breached the Bill of Rights because it denied equal access to the courts, he told the judge. Philip Dykes QC, for the Government, said the collector of taxes had a duty to collect revenue deemed to be due. Disgruntled flat-buyers should not be allowed to delay payment of stamp duty by lodging appeals, he added. The High Court case continues today.