Judgment

GAJENDRAGADKAR, C.J.I. : This group of 12 writ petitions raises a common question about the validity of the Orissa Sales Tax Validation Act, 1961(Act No. 7 of 1961) (hereinafter referred to as the Act). The facts on which the petitioners rely are similar, and so, we shall mention the facts in the first group consisting of writ petitions Nos. 125-135 of 1963. The petitioner in this group is Shri.Epari Chinna Krishna Moorthy, Proprietor, Epari Chinna Krishna Moorthy and Sons, Berhampur, Orissa. He is a merchant who carries on business in "bullion and specie and gold and silver ornaments at Berhampur and as such merchant, he has been registered as dealer under the Orissa Sales Tax Act, 1947. (Act No. 14 of 1947). After the said Act came into force, the Government of Orissa purporting to exercise its authority under S. 6 of the said Sales Tax Act issued a notification exemption certain articles from the operation of the charging section of that Act. Under this notification, gold ornaments were ordered to be exempted from sales-tax when the manufacturer selling them charges separately for the value of gold and the cost of manufacture . This notification was issued on July 1