Common prayer in all these original petitions filed under Article 226 of the Constitution of India is to declare S.29A(2B) of the Kerala General Sales Tax Act and Ext.P2 circular issued by Board of Revenue, ultra vires, unconstitutional, inoperative and invalid. In some of the original petitions, S.29A(2A) is also under challenge.

2. S.29A provides for the procedure for inspection of goods in transit through notified areas or any other place found necessary. Sub-S.(2) authorises the checking officer to detain the goods and permit it to be transported only on furnishing security, provided that he has reason to suspect (i) that the goods under transport are not covered by proper and genuine documents in cases where such documents are necessary. or (ii) that there was attempt to evade tax. Proviso permits him, in appropriate cases, to release the goods on execution of bonds, in cases covered by Sub-s.(2) if it is found that there is collusion for the purpose of evading tax. Sub-s(2A) authorises detention of vehicle also. Sub-s.(2B) contemplates three contingencies. They are concerning reasonable belief on the facts, (i) that tax payable for the sale or purchase of goods und