Change of Boundaries.--Incorporated cities and towns continued to use the authority in the annexation statute to annex by ordinance,'and the courts were presented with several questions of interpretation of the statute not heretofore answered.
Discretion To Annex by Ordinance--The question in Central Soya Co. v. City of Chattanooga was whether or not a municipality when petitioned by "interested persons" must propose extension of its corporate limits by the referendum method.
Burden of Proof in Annexation--Since the action of the municipality is by ordinance, the suit to contest the validity of an annexation ordinance is in the nature of a quo warranto proceeding. In State ex rel. Senff v. City of Columbia the relators, citing cases involving title to office, contended that the burden of proof was on the city to show that the ordinance was reasonable.
Local Government Law -- 1961 Tennessee Survey,
14 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol14/iss4/18