This appeal presents the question, whether there was error in holding that plaintiff cannot maintain this action to foreclose certifi *23 cates of sale of real estate, issued by the sheriff, upon a sale of the lands described therein, and owned by defendant, for the collection of drainage assessments, for that one year had not elapsed from the date of said certificates to the date of the commencement of the action. The contentions of the parties hereto involve but one question, to wit: Does a cause of action under C. S., 8037 accrue in favor of the holder of a certificate issued by a sheriff upon the sale of land for taxes, at the date of such certificate, or only after a year has elapsed from said date? The decision of this question must necessarily be determined by pertinent statutory provisions.

O. S., 5361 provides that drainage assessments shall constitute a first and paramount lien, second only to State and county taxes, upon lands assessed for the payment of same; and that they shall be collected in the same manner and by the same officers as State and county taxes are collected. It is further provided therein that “the existing tax law in force when the sales are made for delinquent assessments shall have application in redeeming lands so sold, and that in all other aspects, except as to the time of sale of lands, the existing law as to the collection of State and county taxes shall apply to the collection of such drainage assessments.”

In section 3 of chapter 88, Public-Local Laws, 1923, amending C. S., 5361, it is specifically provided that “the owner of said lands so sold, or any person having an estate therein, or having a lien thereon, may redeem the same in the manner provided in C. S., 8038 and in O. S., 8039, or any amendment thereof; and if the board of drainage commissioners shall have been the purchaser of said lands, the amount paid in redemption shall include the sum bid therefor plus the penalty.”

The statute relative to the sale of lands for the collection of State and county taxes, C. S., 8010 et seq., provides that it shall be the duty of the sheriff, who has the tax list in hand for collection, to sell the lands of a delinquent taxpayer, and to give to the purchaser a certificate, in writing, under his official seal, in the form prescribed in C. S., 8024. At-any time after one year, and within two years, from the day of sale, upon demand of the holder of such certificate, if the 'land has not been previously redeemed as allowed by law, the sheriff shall execute a deed conveying the land sold and described in the certificate to the purchaser, his heirs or assigns, C. S., 8030. Such deed shall be registered, and shall vest in the grantee, his heirs and assigns the title to the property therein described, C. S., 8033. The holder of the certificate, instead of demanding a deed, to which he is entitled at the expiration of one year from the day of sale, may institute an action in the nature of an action to foreclose a mortgage, and recover thereon a judgment for the sale of the land described in his certificate for the satisfaction of whatever sums may *24 be due him upon his certificate, or of any other amounts for which he has a lien upon said lands. This action must be commenced within two years from the date of the last certificate of sale held by plaintiff. The plaintiff, whether an individual or a corporation, either public or private, shall be entitled to recover interest at the rate prescribed by statute, on all amounts paid out by him. “Such interest shall be computed from the date of each payment up to the time of redemption or final judgment.” C. S., 8037. There is no express provision in the statute fixing the date at which, or after which and within two years, the action to foreclose may be commenced. The right, however, of the landowner to redeem, as allowed by law, is expressly recognized. See Townsend v. Drainage Comrs., 174 N. C., 556.

The right of the owner of land sold for taxes to redeem the same, at any time within one year after the. day of sale,~byipaying to the sheriff for the use of the purchaser, the sum. mentioned in the certificate issued to the purchaseRby the sheriff, with interest thereon at the rate of twenty per centum per annum, together with all taxes subsequently paid, and all costs and expenditures, is secured by C. S., 8038 and C. S., 8039. This right is specifically extended to the owner of land, sold for the collection of drainage assessments. Chapter 88, Public-Local Laws, 1923, sec. 3. We cannot think that it was the intention of the General Assembly to leave the right of an owner of lands sold for taxes or for assessments, to redeem the same, within one year from the date of sale, dependent upon the choice of remedies by the holder of the certificate of sale. A reasonable construction of the statutes pertinent to the question presented by this record/ sustains the opinion in accordance with which the judgment herein was rendered.

An action to foreclose a certificate of sale of real estate, authorized by C. S., 8037, cannot be maintained until after the expiration of one year from the date of the certificates; at any time within said year, the owner of the land may redeem the same by complying with the provisions of C. S., 8038. The action must be brought within two years from said date. This leaves only one year within which the action may be brought. The construction of the statutes as contended by plaintiff would deprive the landowner of the right to redeem within one year — a right expressly secured by statute. Whether such limitation upon the right of the purchaser to maintain an action to foreclose the certificates of sale, issued to him by the sheriff, is in accordance with a wise and just policy or not is for the General Assembly to determine. The judgment herein is

Affirmed.