ALBERT C. RITCHIE, GOVERNOR. 549

be and appear by a certain day in the said order nisi named,
to show cause why said sale shall not be ratified, and a copy
thereof shall be published as the Court shall direct, and if no
objections to the ratification of such sale shall be filed within
the time limit named in said order nisi, or if objection be
filed and the objector is unable and fails to shows that the Tax
Collector has failed to comply with the provisions of this Act,
the sale shall be finally ratified by said Court; and for the
purpose of hearing objections or passing order under this Act.
said Court shall be deemed always to be opened as in Chancery
proceedings; if the objection to sale under this Act shows to
the satisfaction of the Court that the Tax Collector had failed
to comply with the provisions of this Act, said sale shall be
set aside and said Tax Collector shall at once proceed to make
a new sale of the property. Under a ratification of a tax
sale under this Act, the Tax Collector shall convey to the
purchaser the property purchased by him upon the payment
of the costs of such deed by the purchaser; and the bond or
bonds of the Tax Collector shall be liable for the purchase
money paid by the purchasers if the sale be not ratified, with
interest thereon; and for all costs and expenses accruing from
said sale the Tax Collector shall retain out of the proceeds of
said sale when ratified, the amount of taxes and interest thereon
and ail costs incurred in advertising, making, reporting and
ratifying such sale, and shall pay over the excess to the owner
of property thus sold, and no sale under this Act shall be set
aside if the provisions thereof relating to sales shall appear
to have been substantially complied with and the burden, of
proof to show any non-compliance with said provisions shall
be on the exceptant thereto, and when any sale shall have
been finally ratified by the Court, as herein provided, the order
of ratification shall be conclusive as to the regularity of the
Tax Collector's proceedings therein and of said sale, and shall
not be open to inquiry except in case of fraud or collusion in
said proceedings and sale on the part of or between the Tax
Collector and purchaser; every tax deed shall contain the
name of the former owner of the property it conveys and the
Clerk of the Circuit Court in whose office the same may be
recorded shall index it not only in the name of the grantor
and grantee, but also in the name of and as from the former
owner to the grantee; and if taxes be due and owing upon real
and personal property by any taxpayer the whole of said taxes
shall be a lien on said real property, and said real property