Judgment

E. S. VENKATARAMIAH, J.:- These appeals by special leave are filed against the judgment of the High Court of Allahabad in Civil Misc. Writ Petri. No. 339 of 1981 and connected cases delivered on May 25, 1982 : (reported in 1983 Tax LR 2888) holding inter alia that S. 28-B of the Uttar Pradesh Sales Tax Act, 1948 (U.P. Act No. XV of 1948) (hereinafter referred to as the Act) and R. 87 of the Uttar Pradesh Sales Tax Rules, 1948 (hereinafter referred to as the Rules) framed by the Government of Uttar Pradesh in exercise of its powers conferred under the Act, as constitutionally valid and dismissing the Writ Petitions with costs. There are also before us a number of writ petitions presented under Art. 32 of the Constitution in which similar contentions are raised. We are disposing of all the appeals and the connected writ petitions by this common judgment. But we are setting out the facts in one set of appeals for purposes of all these cases as the questions involved are mostly legal issues.

2. The appellants who claim to be engaged in the business of transport of goods belonging to others for hire from one place to another and who in the course of their business have to carry g