JUDGMENT

TULZAPURKAR, J.:— These writ petitions filed by Registered Exporters of Coffee under Art. 32 of the Constitution raise an important question of proper construction of S. 5 (3), a provision newly inserted in the Central Sales Tax Act 1956 by an Amending Act (103 of 1976) and the petitioners also seek to challenge the constitutional validity of a Circular dated February 7, 1977 issued by the Coffee Board, whereby it requires the Registered Exporters of Coffee to furnish contingency deposits or bank guarantees equal to the amount of sales tax in respect of the exempted sales under the said S. 5 (3) and pray for its cancellation or withdrawal and consequential reliefs.

2. The facts giving rise to the writ petitions being common and almost identical may be stated. The Coffee Board, Bangalore is a statutory corporation incorporated under S. 5 of the Coffee Act, 1942, an enactment passed to provide for the development of the Coffee Industry under the control of the Union. Sections 4 to 10 of the Act deal with the setting up of the Coffee Board on which all interests are represented and some Members of Parliament and Government Officers are nominated. The Board exercises powers and