ORDER

1. These are appeals by the State of Karnataka against the judgment and order of the High Court of Karnataka which holds that desiccated coconut is the same as coconut, coconuts being declared goods for the purposes of sales tax.

2. The issue turns, basically, upon the interpretation of Section 14, entry (vi), sub-entry (viii). Section 14 declares the goods therein stated to be of special importance in inter-State trade or commerce. Entry (vi) therein a refers to "ouseeds, that is to say,... (viii) Coconut (i.e., copra excluding tender coconuts) (Cocos nucifera) ".

3. Copra is, in Coconuts : Production, Processing, Products, 2nd Edn. by Jasper Guy Woodroof, stated to be the trade name for dried coconut meat or kernel. The Encyclopaedia Britannica refers to copra as being dried sections of the oil-bearing kernel of the fruit. The less common drying of the intact whole nut kernel produces ball edible or whole copra. For our purposes what is most relevant is, "Shredding of the fresh meat, followed by thorough drying, results in a food item, desiccated coconut, in which the moisture content is somewhat lower and the oil content higher than that of copra".

4. What the respondents