Judgment

GROVER J.:- These eight appeals by certificate arise out of a common judgment of the Rajasthan High Court dismissing the petitions under Article 226 of the Constitution filed by the appellants.

2. The appellants carry on the business inter alia, of manufacture and sale of vests and underwears (Baniyans and Chaddies) out of knitted fabric. On January 31, 1958 a notification was issued by the State Government under Section 4 (2) of the Rajasthan Sales Tax Act, 1950. hereinafter called the "Act, exempting from tax the sale of any garment whether prepared within or imported from outisde Rajasthan the value of which did not exceed Rs.4 in single piece. In spite of the aforesaid notification the authorities did not exempt from payment of sales tax the sale of vests and underwears the value of which did not exceed Rs.4 in single piece. The notification was interpreted to mean that the goods manufactured by the appellants were not garments within its meaning. M/s. Pareek Hosiery Products Jaipur took the matter to the High Court by way of a writ petition under Article 226 of the Constitution which was allowed and it was held that the vests and underwears were covered by the said noti