C. N. RAMACHANDRAN NAIR, J. –

The short question arising in these cases is whether a hospital is a "dealer" within the definition of that term contained in the Kerala General Sales Tax Act, hereinafter called "the Act". The proceedings initiated against the petitioners by the sales tax authorities under the Act under challenge are issued on the basis that the petitioners are "dealers" under the Act. While in some cases notices are issued to the hospitals directing them to take registration under the Kerala General Sales Tax Act, in some cases hospitals are directed to produce books of accounts and in yet another category penalty is levied or proposed either for not registering or for non-compliance with other statutory provisions. The validity or otherwise of all these proceedings will depend on whether the concerned hospital can be treated as a "dealer" to subject it to all the disciplines provided under the Act and Rules. There is a standard pattern of service rendered in a hospital and distinguishing factors among the hospitals may be in regard to quality and volume of it, but essentially the activities in all the hospitals are one and the same. There is no case by any o