JUDGMENT

M. Jagannadha Rao, J.-The appellant before us is the Central Arecanut Marketing and Processing Co-operative Ltd., Mangalore. It was impleaded as the second respondent in Writ Petition No. 15495 of 1981 filed by the respondents 2 to 19 in the Karnataka High Court. The Writ Petition filed in 1981 was allowed after nine years by the High Court by Judgment dated 27.8.1990.

2. The relevant facts of the case are as follows. The Writ Petitioners were all registered dealers under the Karnataka Sales Tax Act, 1957 and claimed to be purchasers of arecanut from local registered dealers by paying Sales tax on the first sale in the State and contended that thereafter they sold the same outside the State of Karnataka and that their sales in the course of inter-State trade and commerce were subject to tax under the Central Sales Tax Act, 1956. While so, a notification was issued on 14/17.9.1997(Sic 14/17.9.1977) under Section 8(5) of the Central Sales Tax Act, 1956 by the State of Karnataka exempting the inter-State sales of tax-suffered arecanut effected by the appellant - Society. The respondent - Writ Petitioners contended before the High Court that the above notification not only imped