The main legal point established in the judgment is the State's discretion in granting exemptions from stamp duty and the principle of reasonable classification in economic legislation.

( 1 ) IN this batch of Writ Petitions, the petitioners have sought for a common relief based upon similar set of facts. Therefore, I propose to hear and dispose of these Petitions by the common following order.

( 2 ) ADMITTEDLY, the petitioners are the employees working in the State of Karnataka in different Departments controlled by the Central government. With a view to construct residential houses on the sites allotted to them by the CIL House Building Co-operative Society limited, they approached the Government of India through the various Departments in which they are working for sanction of loans. According to them, they are low paid employees and they could not afford to pay the higher rentals and therefore they have taken up constructions of their own houses by raising loans.

( 3 ) ACCORDING to the Rules governing such loans, the petitioners are required to execute Mortgage Deeds in favour of Government of india in respect of the sites on whiph loans were granted for construction of houses. Accordingly, Mortgage Deeds were executed some time in the year 1975, 1977 and 1978. After so executing the mortgage Deeds, the petitioners were required by the Head of the department to have their Mortgage Deeds registered in Madras. Therefore, they had to go to Madras by spending a lot of money to have their Mortgage Deeds registered there.

( 4 ) IT is their contention that in Tamil Nadu the employees of the State Government as well as the Central Government were exempted from paying stamp duty on such documents. They also contend that such facility of exempting them from paying stamp duty has also been extended throughout the Country except Kerala and Jammu Kashmir, by the Official Memorandum dated 31-5-1978 issued by Ministry of works and Housing, New Delhi, a copy of which is produced as annexure-B.

( 5 ) HOWEVER, on January, 31, 1985 the petitioners received the orders (Annexures H1 to H8) issued by the Special Deputy commissioner for Detection of Under valuation of Stamps, Bangalore, requiring them to pay deficit stamp duty so as to enable them to have the Mortgage Deeds registered. Aggrieved by the said orders, they approached the Minister concerned in the Karnataka State requesting him to extend the facility in their favour so as to enable them to have their Mortgage Deeds registered, without paying the stamp duty. It appears, they have made repeated efforts to get themselves exempted from payment of Stamp Duty but in vain. It is stated that by virtue of several Notifications issued under Section 9 of the Karnataka stamp Act, 1957 (hereinafter referred to as the 'act') the State government exempted both State and Central, Government employees from paying Stamp Duty on Mortgage Deeds to be executed by them. According to them, earlier by one such Notification the State of Karnataka exempted the employees working in the central Government from payment of stamp duty on Mortgage Deeds in respect of loans raised by them in regard to purchase of Motor Cars and Motor Cycles. Indeed, they have also stated that earliet by virtue of another such Notification issued by the State of Karnataka, the employees working in the Central Government were also exempted from payment of stamp duty on Mortgage Deeds in respect of loans raised from the HUDCO. It is stated that similar concessions were also extended to the employees working in the Defence. It is pointed out that, by virtue of a Notification issued by the State of Karnataka on 19-3-1971 only its employees are exempted 50 per cent Stamp Duty on the Mortgage Deeds, Agreements and Surety Bonds to be executed in favour of the State of Karnataka in respect of house building, house purchase loans or house repair advances granted by it and Central Government Employees are denied such concession. Therefore, it is contended that having regard to this anomaly relating to payment of stamp duty in respect of House Building Loans, the petitioners have approached this Court in the