Thomas, Ag. C. J.

When the original petitions were filed the initial target was the steep rise in the tax amount imposed by the Government on "contract carriages". But eventually petitioners restricted the scope of their challenge to the two tier tax rates fixed on contract carriages - one for those operating service entirely within the State of Kerala and the other for those conducting service both within and outside the State. The former class of contract carriages is described as "intra-state service" for convenience and the latter class as inter-State service". (The same expressions can appropriately be used by us also in this judgment). Tax in respect of intra-State service is Rs. 500/- per quarter per seat while for the other it is just double of it. This differentiation is attacked as violative of Article 14 of the Constitution.

2. Learned single judge dismissed all the Original Petitions on the ground that the said classification has an intelligible basis and that there is nexus between the differentia and the object of the taxation. In other words, learned single judge upheld the validity of the two tier tax measure imposed on contract carriages. Owners of the co