The main legal point established in the judgment is the interpretation of statutory language in fiscal statutes. The court emphasized the importance of considering the popular sense of words, the absence of specific qualifiers, and the context in which the words appeared, and referred to dictionary meanings and previous decisions to determine the ordinary meaning of the statutory language.

The judgment of the court was delivered by

GOVINDAN NAIR, AG. C.J. - The question is how the words "furniture made of iron and steel" in item No. 17 in the First Schedule to the Kerala General Sales Tax Act, 1963, for short, the Act, must be interpreted. Item 17 in its entirety reads as follows :

"17. Safes, almirahs and furniture made of iron and steel."

The goods falling within the item are liable to tax at the first point of sale in the State by a dealer who is liable to tax under section 5 of the Act at the rate of 12 per cent of the turnover.

2. The Tribunal took the view that the goods described in the statement dated 22nd November, 1971, filed by the assessee are not goods falling within item 17 of the First Schedule. For easy reference, that statement is attached hereto, as an appendix.

3. Certain principles are now well-settled : In fiscal statutes, words used must be understood according to their popular sense. Scientific or technical meanings are not generally attributed to words in such statutes. The dictionary meaning of the words need not necessarily be applied invariably. (See the Full Bench decision of this Court in Krishna Iyer v. State of Kerala ([1962] 13 S.T.C. 838)).

4. There is no controversy between counsel for the assessee and counsel for the revenue regarding these principles, but it is contended by counsel for the assessee that, in view of the remand order in T.R.C. No. 27 of 1969, the enquiry in this case is limited to what is the popular meaning that has to be attributed to "furniture made of iron and steel". In other words, counsel contended, the question in this case, at any rate, is not what is the meaning that should be attributed to the words "furniture made of iron and steel" but is only whether, in the popular sense of those words, the equipments (see description in the appendix) that have been sold to hospitals can be called "furniture made of iron and steel". The submission is that a limited meaning must be given to these words and the words understood as referring only to household furniture. This contention presupposes that furniture made of iron and steel has a popular meaning as distinct from its wider dictionary meaning; there being of course no scientific or technical meaning attributable to these words. We have not been referred to any decision which has interpreted identical or similar words or even analogous decisions. When one talks of vegetables, it is easy to conceive of a popular meaning as distinct from the scientific or botanical meaning applicable to a particular commodity. So it is comparatively easier to decide, as in Planters Nut and Chocolate Co. Ltd. v. The King ((1952) 1 D.L.R. 385), that peanuts and cashew-nuts, though they may, from the botanical point of view, be classified as fruits, are excluded from the meaning of the "fruits" and "vegetables" as used in the exemption provisions of the Excise Tax Act, R.S.C. 1927, c. 179. The matter becomes much more difficult when we deal with "furniture" because no popular meaning of the expression "furniture made of iron and steel" is discernible. We have, therefore, to seek for a meaning for these words by reference to the meaning of the word "furniture" in dictionaries. That is the only way of understanding the import of these words. It has not been unusual to apply the dictionary meaning in cases of this nature. So in Commissioner of Sales Tax, Madhya Pradesh, Indore v. Jaswant Singh Charan Singh ([1967] 19 S.T.C. 469 (S.C.)), and more pointedly in Commissioner of Income-tax, West Bengal, Calcutta v. Raja Benoy Kumar Sahas Roy ([1957] 32 I.T.R. 466 (S.C.); A.I.R. 1957 S.C. 768.), the Supreme Court applied the dictionary meaning. The question that arose in the former decision was whether "charcoal" is included in the word "coal". The contentions raised in the case included the submission that "while construing such entries, the dictionary meaning should not be preferred to the popular meaning or the meaning in the