1. These appeals by the State of Kerala are from a common judgment holding that the Kerala Buildings Tax Act, 1961, is ultra vires of Art.14 of the Constitution which provides that the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. Entry 49 in List II (State List) of the Seventh Schedule to the Constitution empowers the State to impose taxes on lands and buildings; and the contention of the State is that the Kerala Buildings Tax Act, 1961, embodies a valid exercise of that power and that it does not in any way violate the equality guaranteed by the Constitution.

2. The Act, as directed in S.1, extends to the whole of the State and has to be deemed to have come into force on the 2nd of March 1961. The charging section is S.4. It consists of two sub-sections and three explanations,

3. Sub-section (1) of S.4 provides that subject to the other provisions contained in the Act, there shall be charged a tax at the rate specified in the schedule to the Act in respect of every building the construction of which is completed on or after the 2nd March 1961 and which has a floorage of one thousand square f