THE FACTS The facts of the case, as submitted by the applicant, may be summarised as follows: The applicant is a citizen of the United Kingdom. He was born in 1933 in England and now resides in Dublin. He is a property developer and surveyor by profession. In May 1934 the applicant was formally adopted in England by a Miss X., a retired nurse. He was married in 1960. His wife is Irish. In March 1963 he moved to Ireland with his wife and his mother by adoption and settled there. In April 1964 his mother died, aged 81. The applicant was left about £20,000 under his mother's will. Under Irish law, legacy duty was payable on this bequest. It appears that the rates of legacy duty in Ireland in 1964 were 1% for the children of the deceased and 10% for "strangers in blood". Under the Adoption Act 1952 it was expressly provided that for the purposes of legacy duty an adopted person was to be considered as the child of the adopter. The 1952 Act did not define the meaning of the term "adopted person", but by the Adoption Act 1964 it was provided that an "adopted person" meant a person in respect of whom an adoption order had been made. The term "adoption order" was itself defined in the 1952 Act as meaning an order made under Section 9 of that Act. Consequently the effect of the two adoption Acts was that only a person in respect of whom an adoption order had been made under the  1952 Act, i.e. a person who had been adopted under Irish law, could claim to be considered as a child of the adopter for the purposes of legacy duty. Since the applicant had been adopted under the relevant provisions of English law he was treated as a "stranger in blood" on his mother's death and was therefore required to pay 10% legacy duty. The applicant was informed by his legal advisers that the only way he might avoid paying duty was if he could show that his mother was not domiciled in Ireland at the time of her death, i.e. that she intended one day to return to England. When the Revenue Commissioners took proceedings against him for payment of the duty he therefore attempted to establish that his mother had been domiciled in England. The High Court rejected this defence and on .. February 1971 ordered that the applicant should pay the 10% legacy duty. The applicant did not appeal against this judgment. He states that he accepts the Court's findings that his mother died domiciled in Ireland and admits that in those circumstances he was obliged under Irish law as it then stood to pay 10% duty. What he cannot accept, however, is that he should be treated any differently from a person adopted under Irish law. It seems that this was his real complaint at the time of the proceedings, but because the relevant provisions of the Adoption Acts were clear, he was not able to put this particular point to the court. Despite the Court judgment against him, the applicant continued to withhold payment. On .. April 1972 he petitioned the Minister for Finance asking for relief. After setting out the facts of his case he stated that he had always been prepared to pay 1% duty. He ended: "I understand that you are willing to consider grievances caused by the anomalies of tax law and hope you will give my petition every consideration". The applicant also wrote to the Dail Deputy for his constituency, who was then Shadow Minister for Finance, requesting his assistance. It seems that it was partly because of the applicant's situation that the Finance Bill 1972 contained a section giving relief for the purposes of death duties to those persons adopted abroad, putting them in the same position as those adopted in Ireland. During the debate on the Bill in the Dail, the applicant's Deputy welcomed this section and stated that he hoped it would be possible to make some retrospective provision. The Minister for Finance replied that because of the difficulties this would lead to it was not possible to make the benefit retrospective. The section was only to apply in respect of anyone dying after the passing of the Act. As a result of representations made on the applicant's behalf the Revenue Commissioners considered the matter again and made their final reply on .. August 1972. The applicant's request for relief was turned down and it was stated that the Commissioners had to proceed to recover the amount due under the High Court judgment. On .. February 1973, after execution proceedings had been started against the applicant and his goods were on the point of being seized, he paid the full amount claimed by the Revenue Commissioners. Complaints The applicant complains that he has been deprived of his possessions on the basis of a discriminatory law. He complains that this has been a humiliating episode for him, not least because of the disrespect it has shown to his family. He submits that the provision in the Finance Act 1972 remedying for the future the anomaly he had exposed should also have been made retrospective. He challenges the argument of the Finance Minister that this would have created too many difficulties and points out that relief given in similar circumstances by the Finance Act 1960 to children informally adopted was made retrospective to 1 January 1953. The applicant alleges the violation of Article 1 of Protocol No. 1 in conjunction with Article 14 and Article 1 of the Convention. He states that his object is to achieve equality for all purposes with persons of equal status, namely persons adopted under Irish law. THE LAW 1.   The applicant has complained that on the death of his mother, who had adopted him in England, he has had to pay ten times as much legacy duty as a child adopted in Ireland would have paid. He alleges that he has thereby been deprived of his possessions on the basis of a discriminatory law, in violation of Article 14 (Art. 14) of the Convention in conjunction with Article 1 of Protocol No. 1 (P1-1). Article 1 of Protocol No. 1 (P1-1) provides that:  "Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law. "The preceding provisions shall not, however, in any way impair the right of a State to enforce such laws as it deems necessary to control the use of property in accordance with the general interest or to secure the payment of taxes or other contributions or penalties." Article 14 (Art. 14) lays down that the enjoyment of the rights and freedoms set out in the Convention shall be secured without discrimination on any ground such as, inter alia, national origin, birth or other status. The Commission finds first that there is no question of there having been a breach in this case of Article 1 of Protocol No. 1 (P1-1) taken alone and notes that such a violation has not even been alleged by the applicant. The interference with the peaceful enjoyment of the applicant's possessions was clearly covered by the saving provisions of this article. The Commission has gone on to consider whether there might nevertheless have been a possible violation of this article in conjunction with Article 14 (Art. 14) of the Convention, bearing in mind the ruling of the Court in the Belgian Linguistic Cases that : "measure which in itself is in conformity with the requirements of the article enshrining the right or freedom in question may, however, infringe this article when read in conjunction with Article 14 (Art. 14) for the reason that it is of a discriminatory nature". The Court went on to say that:  "In spite of the very general wording of the French version ("sans distinction aucune"), Article 14 (Art. 14) does not forbid every difference in treatment in the exercise of the rights and freedoms recognised ... It is important then, to look for the criteria which enable a determination to be made as to whether or not a given difference in treatment, concerning of course the exercise of one of the rights and freedoms set out in the Convention, contravenes Article 14 (Art. 14). On this question the Court ... holds that the principle of equality of treatment is violated if the distinction has no objective and reasonable justification". (Judg. Court, 23 July 1968, paragraphs 9 and 10.) Since the applicant has shown that he has been treated differently from persons adopted under Irish law the Commission has examined whether this difference of treatment had such an objective and reasonable justification. The Commission observes here that for the purposes of taxation laws there are bound to be numerous distinctions between different categories of persons. The Commission's function, in the light of the above ruling of the Court, is to consider whether such distinctions are discriminatory as being arbitrary and without reasonable justification. In the present instance the Commission notes that, for the purpose of fixing the scale of legacy duty payable by adopted children, the relevant test laid down by Irish law, prior to the Finance Act 1972 was whether the child concerned had been adopted under the provisions of Irish law or of foreign law. Bearing in mind the differences in the conditions for adoption and in adoption procedures from one country to another and the differences in status resulting from such adoption, the Commission finds that this test was reasonable and objective and therefore not discriminatory. An examination by the Commission of this complaint as it has been submitted does not therefore disclose any appearance of a violation of the rights and freedoms set out in the Convention and in particular in the above two articles. It follows that this part of the application is manifestly ill-founded within the meaning of Article 27, paragraph (2) (Art. 27-2), of the Convention. 2.   The Commission has also considered the applicant's complaint that this difference in treatment showed disrespect to his family. The Commission has examined ex officio whether there might thereby have been a violation of Article 14 (Art. 14) in conjunction with Article 8 (Art. 8) of the Convention, which provides that everyone has the right to respect for his private and family life. It is true that, as a person adopted under a foreign law, the applicant has been accorded a less privileged status than persons adopted under Irish law. However, for the same reasons as those expressed above, the Commission finds that this difference in treatment was based on an objective and reasonable criterion and thus not discriminatory. An examination by the Commission of this complaint as it has been submitted, including an examination made ex officio, does not therefore disclose any appearance of a violation of Article 14 (Art. 14) in conjunction with Article 8 (Art. 8) of the Convention. It follows that this part of the application is likewise manifestly ill-founded within the meaning of Article 27, paragraph (2) (Art. 27-2), of the Convention. For these reasons, the Commission DECLARES THIS APPLICATION INADMISSIBLE