Supreme Court of India
UNION OF INDIA & ORS.versusRAMACHANDRA SAMBHAJI KANDEKAR ETC.
- Citation
- 1980 INSC 162
- Decided
- 26 August 1980
- Disposal
- Appeal(s) allowed
- Bench
- P N BHAGWATI
Holding
The third proviso imposes a higher rate of excise duty on manufacturers who first commenced production on or after 1 April 1961, irrespective of when the powerlooms were acquired, and it overrides the exemption granted by the second proviso.
Summary
The respondents, each owning no more than four powerlooms acquired from licensed manufacturers, claimed exemption from excise duty on cotton fabrics under Item 7 of the 1957 exemption notification. The Central Government had introduced a series of provisos, the third of which (effective 1 April 1961) stipulated that any manufacturer who commenced production for the first time on or after that date and had acquired powerlooms from a licensee would be liable to pay duty at the next higher rate. The respondents argued that a later second proviso (effective 20 April 1961) exempted manufacturers employing up to four looms in a single shift, thereby shielding them from duty. The Court held that the date in the third proviso refers only to the commencement of production, not to the acquisition of looms, and that the third proviso creates a substantive duty which overrides the second proviso. Consequently, the respondents who began production on or after 1 April 1961 are liable to pay excise duty at the higher rate, despite the number of looms or shifts. The Supreme Court allowed the appeals, set aside the High Court judgment and remanded the matters for disposal in accordance with this interpretation.
Issues considered
- Whether the phrase ‘on or after 1 April 1961’ in the third proviso relates solely to commencement of production or also to acquisition of powerlooms.
- Whether the third proviso, which imposes a higher rate of excise duty, overrides the second proviso that exempts manufacturers using not more than four powerlooms in a single shift.
- Whether respondents owning up to four powerlooms and operating a single shift are liable to pay excise duty at the higher rate under the third proviso.
Legislation cited
- Central Excise Act, 1944s. 3, s. 37(2)
- Central Excise Rules, 1944s. Rule 8(1), s. Rule 96-J
Subjects
excise dutyexemptionpowerloomstatutory interpretationhigher rateprovisoCentral Excise ActCentral Excise Rules
Judgment
'··
L
513
A
\UNION OF INDIA & ORS.
v.
RAMACHANDRA SAMBHAJI KANDEKAR ETC.'
B
August 26, 1980
[P. N. BHAGWATI, A. P. SEN & E. S. VENKATARAMIAH, JJ.]
Central Excise Rules 1944-Rule 8(1) Item 7-provisos-Scope' of-
Exercising the power of exemption conferred under rule 8(1) of the Central
~Excise Rules, 1944, the Central Government by a notification dated January 5,
c
1957 exempted certain varieties of cotton fabrics from the whole of the excise
·duty leviable thereon. Item 7 set out one of such varieties as under: "Cotton
·fabrics produced ............... powerlooms ............ provided that the number of
:power!ooms producing cotton fabrics in such factories does not exceed four."
By a notification dated November 26, 1960 a proviso was added to this D
item stating that "this exemption shall not be applicable to a manufacturer who
·Commences production for the first time on or after the December 1, 1960 by
acquiring powerlooms from any other person who is or has been a licensee
of a powerloom factory.". From March 1, 1961 item 7 was substituted and
·from April 1, 1961 a proviso was added. to item 7, the effect of both, of which.
·was that while from 'March 1, 1961 the benefit of exemption from excise duty
was available only to those manufacturers who had not more th~n two power·
.looms in their factories, from and after. Aprit' 1, 1961 even this limited exemp·
E
tion was withdrawn from manufacturers who ·commenced production for the
•first time on or after April 1, 1961 by acquiring powerlooms from any person
who was or had been a. licensee of powerloom factory.
From March 18, 1961 a second proviso to item 7 was added which provides
·"where a person employs not more than four powerlooms and the said pm,er·
'looms are worked in not more than one shift no duty shall be payable in
F
·respect thereof".
From April 1, 1961 a third proviso was added stating "where a person
·Commences manufacture of the said fabrics for the first time on· or after April 1,
1961 by acquiring powerlooms from any other person who is or has been
a licensee of powerloom factory the rate per shift per month per powerloom
·shall be the next 'higher rate if any". G
The respondents had acquired powerlooms after April 1, 1961 from persons
who were or had been licensees and ·were manufacturing cotton fabrics on
those powerlooms prior to April I, 1961. They claimed that since each of
·them had not more than four powerlooms. which worked in not more than
one shift he was exempt from payment of excise duty by virtue of the second
-proviso to item 7. H
The Superintendent df Central .Excise on the other hand contended that
·the third proviso carved out an exception from the second proviso and since
' ,,
514 SUPREME COURT REPORTS ll98ll 1 S.C.R:-
each of the respondents commenced manufacture of cotton fabrics for the
first time after Apl'.il I, 1961 he was not exempt from· payment of excise duty
but was liable to pay duty at the next higher rate· provided in the amended
notification of March 18, 1961.
Appeals of the respondents having been rejected by the Assistant Collector
and the Collector they filed writs in the High Court challenging the levy of
B excise duty. Their writ 'petitions were allowed by the High Court.
Allowing the appeals
HELD : (!) It is a well settled rule of. interpretation applicable alike to·
the rule making authority as to the legislature that where there are two expres-
sions which could have been used to convey a certain· intention, but one of
c these expressions conveys that intention less clearly than the. other, it is proper
to conclude that if the draftman used that one of the· two expressions which·
would convey the intention less clearly, he does not intend to convey that
intention at all. [523 A]
It is clear on a plain grammatical construction of the proviso under Item T
of the Notification dated 5th January, 1957 that the prescription of the date
D !st April, 1961 has reference only to commencement of production of the cotton
fabrics and not to the acquisition of the powerlooms. What is ;required is that
the production of cotton fabrics must have been commenced by the manufac-
turer for the first tim<: on or after !st April, 1961 and not that the powerloom~ I
also must have been acquired by him on or after that date. [520C'D]
2 (a) Even . though each of the respondents owned not more than four
E powerlooms he would be liable 'to pay excise duty at the next higher rate
under the third proviso to the notification dated March 18, 1961, if he started
manufacture of cotton fabrics on his power!ooms for the first time on or after
April I, 1961, irrespective whether he acquired the powerlooms from a licensee.
before or after that date. [522 C-D]
(b) The exemption under item 7 is not applicable to a manufacturer who
has commenced his production of cotton fabrics for -the first time on or after
F April I, 1961, by acquiring powerlooms from another person who is or has
been a licensee of a powerloom factory. Two conditions which must ~xist
before the mischief of the proviso is attracted are·: (!) the manufacturer must
have commen~ed production of cotton fabrics for the first time on or after
April I, 1961 and (2) the powerlooms on which he manufactures cotton fabrics
must have been acquired by him from a person- who is or has been a licensee
of a powerloom factory. The event which attracts the applicability of the
G proviso is that the manufacturer should have commenced production of cotton
fabrics on these powerlooms for the first time on· or after April I,. 196L If
this condition is satisfied the proviso comes into· play and withdraws t.he
exemption which would otherwise have been available to the manufacturer.
under item 7. [519 H-520 B, E]
(3) The language: and structure of the third proviso being identical with the.
H language and structure of the proviso unde~ item 7 _of the notification Elated·
5th January, 1957 the same. view must govern the interpretation of the third:
proviso. [521 E]
UNION V, R. SAMBHAJI (Bhagwati, J.) 515
The third proviso on its proper interpretation, enacts a substantive pro~ision
for payment of excise duty at the next higher rate in the cases therein speci-
fied and this substantive provision overrides the second proviso which exempts
a manufacturer employing not more than four powerlooms and working not
more than one shift from payment of excise duty in those cases which: do
not falJ within the- third proviso and where a case, is covered by the third
proviso the second proviso wonld be inapplicable and the manufacturer would
be liable to pay excise duty at the next higher rate .. [522 A-BJ B
CIVIL APPELLATE JURISDICTION : Civil Apptal Nos. 1285-1296 of
1970.
Appeals by Special Leave from the Judgment and Order dated
6-3-19ti9 of the Mysore High Court in W.P. Nos. 2560-61 /66 and 46,
C·
47, 50, 51, 975, 1718, 1719, 1921, 1979 and 1980/67.
G. L. Sanghi, M. N. Shroff and Miss A. Subhashini for the Appel-
lants.
R. B. Datar for the Respondent.
D
The Judgment of the, Court was delivered by
BHAGWATI, J.-These appeals by special leave are directed against
the judgment of the Karnataka High Court allowing 12 writ. petitions
filed by different respondents. Each of the respondents owned at the
material time not more than 4 powerlooms and carried on business of
manufacturing cotton fabrics on those Powerlooms. The case of the E
respondents was that each of them acquired his powerlooms from person
who were or had been licencees and started manufacturing cotton
fabrics on those powerlooms prior to 1st April, 1961. The respondents
claimed that sine~ each of them had not more than 4 powerlooms in
his factory, no excise duty was payable on the cotton fabrics manu-
F
factured by him and this claim for exemption was based on a notifica-
tion dated 5th January, 1957 issued by the Government of India in
exercise of the powers conferred upon it by Rule 8(1) of the Central
Excise Rules, 1944. l;he Superintendent of Central Excise, however.
rejected the claim for exemption on the ground that though the power-
looms owned by each of the respondents were not more than 4, manu- G
facture of cotton fabrics on them had started after 1st April, 1961 and
none of the respondents was, therefore, entitled· to exemption from
payment of excise duty on the cotton fabrics manufactured by him.
The excise. duty was accordingly levied on each of .the respondents by
the Superintendent of Central Excise and this levy was confirmed in
appeal by the Assistant Collector and in further appeal by the Collector H
of Central Excise. Each of the respondents thereupon preferred a
writ petiti~n in the Kamataka High Court challenging the levy of excise
516 SUPREME COURT REPORTS [1981J 1 S.C.R.
A duty and praying t~at a writ of mandamus may be issued against the
Excise Authorities directing them not to enforce the notice demanding
excise duty. The writ petitions were allowed by the High Court and
hence the Union of India preferred the present appeals after obtaining
special leave from this Court.
B Before we proceed to examine the rival contentions of the parties
in regard to the controversy arising in these appeals, it is necessary
to ·set out briefly the relevant' provisions of law having a bearing on
this controversy. The Central Excise and Salt Act, 1944 by section 3
read with Item 19 provided for l~vy of excise duty on all varieties
j
of cotton fabrics including cotton fabrics manufactured on powerlooms.
s~ction 37 sub-section (2) of the Act conferred power on the Central
Government to make Rules providing for a number of matters including
inter alia clause (xvii) which was in the following terms :
"Exempt any goods from the whole or any part of duty
imposed by this Act." ·
D The Central Government in exercise of this rufo-making power made
the Central Excise Rules, 1944 of which Rule 8 clause (1) provided
that "the Central Government may from time to time by notification
in the official G!tzette exempt, subject to such conditions· as may be
specified in the notification, any excisable goods from the whole or
any part of the duty leviable on such goods." In exercise of this
E power of exemption conferred under Rule 8 clause (1), the Central
Government issued a notification dated 5th January. 1957 exempting
certain varieties of cotton fabrics from the whole of the excise duty
leviable thereon and one of such varieties set out in Item 7 was as
under:
F "Cotton fabrics produced ·in factories commonly known as
powerlooms (without spinning plants) provided that the number
of powerlooms producing cotton fabrics in such factmie~ does not
exceed four."
This item was later SU bstituted by another item by a notification of
the Central Government dated 19th January, 1957 and the substituted
G
item was as follows :
· "Cotton fabrics manufactured by or on behalf of the same
person in one or more factories .commonly known as powerlooms
(without spinning plants), in which less than 5 powerlooms in all
are installed. 1' .
H The scope of the exemption granted under this item was restricted by
the addition of the following proviso by a Central Government noti-
fication dated 26th November. 1960 :
.. ·, ;[- ' .~
UNION v. R. SAMBHAJI (Bhagwati, J.) 517
"Provided that this exemption shall not be applicable to a A
manufacturer who commences production of the said fabrics for
the first time on or after the 1st December. 1960 by acquiring
powerlooms from any other person who is. or has been a licensee
'Of powerloom factory." •
There was a further change made by a notification issued by the Central B
Government on 1st March, 1961 and the then existing Item 7 was
substituted by the following Item :
"(7) Cotton fabrics manufactured by or on behalf of the same
person in one or more factories commonly known as powerlooms
(without spinning plants) in which less thari 3 powerlooms in all
but not roller locker machine are installed." c
The result was that the exemption granted under Item 7 was consi-
derably narrowed down and the proviso ta_king away the exemption
in certain cases was deleted. But again, by a notification dated 1st
April, 1961, the Central Government introduced the following proviso
under Item 7 : D
"Provided that this exemption· shall not be applicable to a
manufacturer who commences production of the said fabrics for
the first time on or after the 1st April, 1961 by acquiring power-
looms from any other person who is or has been a licensee of
powerloom factory."
E
Thus from 1st March, 1961 the benefit of the exemption from excise
duty was available only to those manufacturers who had not more
than 2 powerlooms in all in !!heir factories and from and after 1st
April, 1961 even this limited exemption was withdrawn from manu-
facturers who commenced production of cotton fabrics for the first
time on or after 1st April, 1961 by acquiring powerlooms from any F
person who was or had been a licensee of p::iwerloom factory.
Now in the present appeals each of the respondents owned ad-
mittedly not more than 4 powerlooms, but it does not appear from
the record before us as to whether any of them owned more than 2
powerlooms. If it is found that any of 'the respondents owned more G
than 2 powerlooms, he would not be within the exemption granted
under Item 7 of the amended Notification dated 5th January. 1957
and excise duty would be payable on the cotton fabrics manufactured
by him. But even if any of the respondents owned not more than
2 powerloqms and was, therefore, within the exemp'tion granted under
Item 7 of the amended notification dated 5th January, 1957, the ques- H
tion would ·still arise whether he forfeited the exemption by reason
.of the proviso to Item 7 introduced by the no'tification dated 1st
518 SUPREME COURT REPORTS fl 981] 1 S.C.R.
A April, 1961. The answer to this question would depend upon the·
true construction of the proviso and we shall presently consider this:
question, but before we do so, it is necessary to refer to some other
notifications issued by the Central Government under the Central'
Excise Rules, 1944.
B On 1st March, 19611 the Central Government in exercise of the
power conferred upon it under Rule 96-J of the Central Excise Rules,
1944 issued a notification providing for a compounded levy scheme
for payment of excise duty on cotton fabrics. By this notification,
the Central Government fixed different rates "per shift, per month,
per powerloom employed by or on behalf of the same person in the-
c manufacture of cotton fabrics" depending upon the number of power-
1ooms employed by such person. The rates prescribed for a case·
where more than 2 but not more than 24 powerlooms were employee'
were Rs. 20 where medium and/or coarse fabrics were manufactured'
and Rs. 25 where the powerlooms were employed in the manufacture-
of superfine and/ or fine fabrics. There was a p~oviso. at the foot
D of the notification (hereinafter referred to as the first proviso) which
laid down as to· how the computation should be made where roller
locker machines were employed. The rates prescribed for a case·
where more than 2 but not more than 24 powerlooms were employed.
were partially modified with· retrospective. effect by a subsequent
notification issued by the Central Government on 18th March, 1961
E
and the new rates were Rs. 10 and Rs. 12.50 in respect of the first
4 powerlooms and Rs. 20 and Rs. 25 in respect of the balance. The
first proviso dealing with the case where roller locker machines were
employed however, remained unchanged. Then came ;mother noti-
fication of ·the Central Government dated 1st April, 1961 by which
F the notification dated 18th March, 1961 was amended by substituting
the words "where more than 2 ·but not more than 24 poweriooms are
employed" by the: words "where not more than 24 powerlooms are
employed" and adding a further proviso (hereinafter referred to as:
the third proviso) after the existing first proviso :
"Provided also that where a person commences manufacture
G
of the said fabrics for the first time on or after the 1st April. 1961.
by acquiring powerlooms from any other person who is, or· has•
been. a licensee. of powerloom factory, the rate per shift, per month.
per powerioom shall be the next higher rate, if any."
This was followed by a notification dated 20th April, 1961 issued by
H the Central Government by which after the first proviso, the following
proviso (hereinafter referred to as the second proviso) was inserted illl
the rlotification dated 18th March, 1961 :
I
'.--:~
UNION v. R. SAMBHAJI (Blwgwati, J.) 519
"Provided further that where a person employs not more than
four powerlooms and the said powerlooms are worked in not more
than one shift, ·no duty shall be payable in respect thereof.;'
The result was that from 18th March. 1961 upto 1st April, 1961, a
manufacturer having more than two but not more than 24 powerlooms
was liable to pay excise duty at the rates set out in the amended noti·
fication dated 18th March, 1961 :ind from 1st April, 1961 to 21st April,
1961. the position was that if such a manufacture~. was found to have
commenced manufacture of cotton fabrics for the first time on or after
. -, 1st April, 1961 by acquiring powerlooms from another person who was
or had been a licensee of powerloom factory, the rate at which excise
duty would be payable by him would be the.next higherrnte specified
in the amended notification dated 18th March. 1961. So far as a
manufacturer having two or less powerlooms was concerned, he was
during the period from 18th March, 1961 upto 1st April, 1961 exempt
from excise duty by reason of the notification dated 5th January, 1957,
but from 1st April, 1961 to 21st April, 1961 this exemption stood with-
,D
drawn if it was found that the manufacturer had commenced manu-
facture of cotton fabrics for the first time on or after 1st April, 1961
by acquiring powerlooms from another person who was or had been
a licensee of powerloom factory ·and in such a case a manufacturer
would be liabfo to pay excise duty at the next higher rate prescribed in
the amended notification dated 18th March, 1961. This was the position E
which obtained upto 20th April, 1961, when the second proviso was
introduced exempting a manufacturer employing not more than 4 power-
1ooms and working even in not more thifn one shift from payment of
excise duty. Each of the respondents had admittedly not more than
4 powerlooms and it was the case of the respondents that these power-
looms were worked in not more than one shift and hence the respon· F
dents .claimed that they were exempted from liability for payment of
excise duty by virtue of the second proviso. But the answer made on
behalf of the Revenue was that the third proviso carved out an excep-
tion from the second proviso and since each of the respondents com-
menced manufacture of cotton fabrics for the first time after 1st April,
1961, he was not exempt from payment of excise duty, but was liable G
to pay the same at the next higher rate provided in the amended noti·
fication dated 18th March, 1961.
Now going back to the proviso under Item 7 of the· notification
dated 5th January, 1957, we find that the language of this proviso is
clear and explicit and does not aomit of any doubt or equivocation. ff
It says in so many terms that the exemption under Item' ·7 shall not
be applicable to a manufacturer who has commenced his production
520 SUPREME COURT REPORTS [1931] 1 S.C.R.
of cotton fabrics for the first time on or after 1st April, 1961 by
acquiring powerlooms from another person who is or has been a licen-
see of powerloom factory. There are two conditions which must exist
before the mischief of the proviso is attracted. One is that the manu-
facturer must have commenced production of cotton fabrics for the
first time 'on or after 1st April, 1961 and the other is that the power-
looms on which he manufactures cotton fabrics must have been acquired
by hi!.11 from a person who is or has been a licensee of powerloom
.·-4
factory. It is clear on a plain grammatical construction that the pres-
cription of the date, 1st April, 1961, has reference only to commence-
ment of production of the cotton fabrics and not to the '.lcquisition of
the powerlooms. What is required is that the production of cotton
fabrics must have been commenced by the manufacturer for the first
time on or after 1st April, 1961 and not that the powerlooms also must
have been acquired by him on ot after that date. It is immaterial as
to when the manufacturer acquired the powerlooms; he may have
acquired them prior to 1st April, 1961; that is totally irrelevant. The
:n only attribute that the powerlooms must satisfy is that: they must have
been acquired from a person who is or has been a licensee of power-
loom factory and if this attribute is present, then it is of no consequence
as to when the powerlooms were acquired by the manufacturer. The
event which then attracts the applicability of the proviso is that the
manufacturer should have commenced production of cotton fabrics on
these powerlooms for the first time on or after 1st April, 1961. If this
condition is satisfied, the proviso comes into play and withdraws the
exemption which would otherwise have been available to the manu-
facturer under the main Item 7. If the intention of the Central Gov-
ernment in framing the proviso was that not only the production of
cotton fabrics on the powerlooms should have commenced on or after
1st April, 1961, but that the powerlooms also should have been ac-
quired by the manufacturer on or after that date, the Central Govern-
ment could have easily expressed such intention by using appropriate
language in the proviso. The Central Government could have trans-
posed the words "on or after the 1st April, 1961" and put them at the
end of the proviso. That would have clearly conveyed the intention of
the Central Government that the powerlooms must be acquired by the
manufacturer on or-after 1st April, 1961 and if the powerlooms
are acquired on or after 1st April, 1961, it must follow a fortiorari
that the production of cotton fabrics on the powerlooms by the manu-
facturer would necessarily commence on or after that date. But the
H Central Government advisedly placed the words "on or after the 1st
April, 1~61" after the clause referring· to commencement of production
and before the clause relating to acquisition of powerlooms. It is a
UNION v. R. SAMBHAJI (Bhagwati, J.) 5 21
well settled rule of interpretation applicable alike to the rule making A
authority as to the legislature that where there are two expressions
which could have been used to convey a certain intention, but one
-t· of these expressions conveys that intention less clearly than the other,
it is proper to conclude that if the draftman used that one of the two
expressions which would convey the intention Jess clearly, he does not
intend to convey that intention at all. Moreover, here the dictates B
of grammar as well as language compel us to take the view that the
date 1st April, 1961 has reference only to commencement of pro. duc.tion
and not to acquisition of the powerlooms. It is to our mind clear
that if a manufacturer is found to have commenced production of
. cotton fabrics on powerlooms for the firs:~ time on or after 1st April,
1961, he would fall within the mischief of the proviso and it would be
c
~ entirely immaterial as to when he acquired ,the powerlooms, whether
before or after 1st April, 1961, so long as the powerlooms are acquired
from a person1who is or has been a licensee of powerloom factory; The
High Court was, therefore, clearly in error in cons'truing the language
of this proviso to mean that the powerlooms also must have been ac-
quired by the manufacturer on or after 1st April, 1961 in order to
attract the applicability of the proviso.
The same construction must obvioi1sly be placed on the third
proviso introduced in the notification dated 18th March, 1961 by the
notification of 1st April, 1961. The language and structure of the
third proviso are identical with the language and structure of the pro-
viso under Item 7 of the notification dated 5th January, 1957 and
the .same view must, therefore, govern the interpretation of the third
J-..
proviso. It is unnecessary to repeat what we have said in the fore-
going paragraph, because what we have said there applies fully and
completely in regard to the interpretation of the third proviso and, F
therefore, in order to determine whether this proviso is applicable to
any of the respondents, we have to consider whether the respond~nt
concerned commenced manufacture of cotton fabrics on the power-
looms for the first time on or after 1st April, 1961, irrespective whether
he acquired the powerlooms before or after that date. The only rele-
vant inquiry necessary to be made is as to when the manufacturer of G
cotton fabrics on the powerlooms was commenced for the first time by
the respondent. If it was on or after 1st April, 1961, the mischief of
the third proviso would be attracted and the respondent would be
liable to pay excise duty at the next higher rate. Of course, the second
proviso introduced in the notification dated 18th March, 1961 with
·effect from 20th April, 1961 provided that where a person employs H
not more than 4 powerlooms and these powerlooms are worked in not
more than one shift, no excise duty shall be payable'. in respect thereof,
522 SUPREME COURT REPORTS (1981] 1 S.C.R.
but the third proviso on its proper interpretation, enacts a substantive
provision for payment of excise duty at the next higher rate in the
cases therein specified and this substantive provision overrides the
second proviso. The second proviso exempts a manufacturer employ-
ing not more than 4 powerlooms and working not more than one shift
from payment of excise duty in those cases which do not fall within
the third proviso ·and where a case is covered by the third proviso, the
second proviso would· be inapplicable and the manufacturer would be
liable to pay excise duty, at the next higher rate. This is the only way
in which the two provisos can be harmoniously construed in a manner
which would give effect to bdth. ,_
A .
.c We are, therefore, of the view that even though each of the respon-
dents in the present case owned not more than four powerlooms, he
would be liable to pay excise duty at the next higher rate under the
third proviso to the notification dated 18th March, 1961, if he started
manufacture of cotton fabrics on his powerlooms for the first time on
or after 1st April, 1961, irrespective whether he acquired the power-
Jooms from the licensee before or after that date. We must, therefore,
set aside the judgment of the High Court and send the matter back
to the High Court so that the High Court may decide the writ petitions
of the respondents in accordance with law and in the light of the
observations contained in this judgment.
We accordingly allow the appeals, set aside the judgment of the
High Court and remand the writ p~titions to the High Court for dis-
posal in accordance with the law. Though the appellants have succeed-
ed, they will pay the costs of the respondents as provided in the order
granting special leave.
:N.K.A. Appeals allowed.
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