JUDGMENT

KAILASAM, J.:— These three appeals are by special leave granted by this Court against the judgment and order of the High Court of Kerala in Writ Appeals Nos. 451. 630 and 807 of 1969 respectively. The questions that arise for consideration in all the three appeals are the same and can be dealt with together. As the facts so far as they are necessary for decision in these appeals are similar, we will confine the judgment to the facts in Civil Appeal No 437 of 1970.

2. The appellant in Civil Appeal No. 437 of 1970 is Travancore Tea Co. Ltd, Vandiperiyar in Kerala State. The 1st respondent is the State of Kerala and respondents Nos. 2 to 4 are the authorities functioning under the Kerala Motor Vechicles Taxation Act (Act 24 of 1963) which will hereafter be referred to as the Act, was brought into force on 1-7-63. The Act provides that "a tax at the rates fixed by the Government by notification in the Gazette not exceeding the maximum rates specified in the First Schedule shall be levied on all Motor Vechicles used or kept for use in the State." The appellant company owned 17 motor vehicles, tractors, trailers and lorries all of which are registered in the companys name under t