1. The removal of "Tapioca" from item 10 of the III Schedule of the Kerala General Sales Tax Act, 1963, by Act 22 of 1974 (with effect from 171974) and its insertion as a specific item in entry No. 72 of Schedule I by the same Act have been challenged in these cases as violative of Art.301 and 14 of the Constitution. S 5 of the Act is the charging Section, which imposes the tax at the rates and only at the points specified, against the goods enumerated in the First or the Second Schedules; and in the case of other goods, at the rate of 4% at all points of sale. (We leave out as unnecessary the minimum limits of turn-over subject to which the tax has been imposed). S.9 of the Act grants exemption to a dealer who deals with the goods specified in the III Schedule to the Act, from payment of tax in respect of the sale and purchase of such goods. Till 1974, item 10 of the III Schedule read:

10 Vegetables (other than green ginger), whether roots, green fruits or leaves, used for human consumption including tapioca, yam, potatoes, lime, sabola and tomatoes, except their manufactured products.

Explanation: The term "vegetables" shall not include any goods of the description spec