Judgment

V.N. Khare, J.-Leave granted.

2. This group of Civil Appeals is directed against the separate judg­ments and orders passed by the High Court of Orissa whereby the High Court has allowed the Writ Applications filed by the respondents, and further directed the appellants herein to issue necessary sales tax exemption certificate in favour of the respondents under Industrial Policy Resolution 1989 (in short IPR 1989), issued by the State of Orissa. Since common questions of facts and law are involved in this group of appeals, we propose to decide these appeals by a common judgment, noticing the facts of leading case Civil Appeal No. 364/94.

3. The State of Orissa, appellant No. 1 herein, had been issuing IPRs from time to time and for the purpose of the present case we are concerned with IPR 1986 and IPR 1989. The basic purpose for issuing IPRs by the State of Orissa was to maintain and enhance the growth of industrialization in the State by giving incentives/concessions to the industries which were set up within its State. Each one of these Policy Resolutions has a cut off date called “effective date” and it remained valid till the announcement of next Policy Resolution, excep