The use of the word "raw" in the phrase "following raw materials" in notifications granting exemption from octroi duty to a particular industry is surplus and redundant. The notifications should be interpreted to extend the exemptions to all the items mentioned therein, including chemicals, fuels and lubricants, packing materials, and other items, in order to further the object of the notifications and avoid absurdity.

( 1 ) THIS special appeal under Section 18 of the Rajasthan High Court Ordinance, 1949 is directed against the Judgment of a learned single Judge of this Court dated Nov. 21, 1980 whereby the learned single Judge has dismissed the writ petition filed on behalf of the petitioner-appellant.

( 2 ) HOWEVER, while interpreting the two Notifications dated 31/05/1966 and 12/07/1966 issued by the Govt. of Rajasthan, the learned single Judge has observed:"having regrd to the context of the two notifications and having regard to the accepted construction which has been placed on the two notifications, I am of the opinion that the notifications should be so construed so as to extend the exemptions to all the items mentioned therein. This may be done either by treating the word raw as surplusage in the opening part or by treating that the raw materials have been defined so as to cover all the items in all the sub-heads of the two notifications. The power of granting as well defining exemptions is vested in the State Govt. under Section 107 sub-s. (5) of the Act. it was further held by the learned single Judge that the orders Exs. 3, 4, 5 and 6 do not deserve to be quashed. He has further held that challenge to the notifications mentioned in Scheule c was not pressed before him. The learned single Judge has further held as under: although, it may be observed that the tenure of notifications in Schedules a and b is 10 years or till a policy decision is taken by the Govt. on the report of the High Power Committee whichever is earlier. On behalf of the petitioner, no material has been placed on record that any report was submitted by the High Power Committee and on such a report, a policy decision was taken and in pursuance of that policy decision, notifications in Schedule c were issued. Apart from that, the notifications in Schedule c are general in nature whereas the notifications of Schedule a and b relate to an individual i. e. respondent No. 3 and these notifications cannot be said to have been superseded, by notifications mentioned in Schedule c. Thus, the last notification in Schedule c cannot be taken to over-ride or supersede the notifications in Schedules a and b. "

( 3 ) A very short question, that is involved in this appeal, is as to whether the use of the word raw materials as used in the Notifications dated 31/05/1966 and 12/07/1966 mentioned in Schedules a and b cover the entire items mentioned in these Notifications as regards exemption of octroi duty?

( 4 ) WE have heard Mr. D. R. Bhandari, the learned counsel appearing for the appellant, Mr. D. R. Bohra, the learned Deputy Govt. Advocate and M/s. L. R. Mehta and R. Mehta, the learned counsel appearing for respondent No. 4 and have carefully gone thorugh the record of the case.

( 5 ) TO decide the controversy involved in this case, it will be very useful to quote the Notifications dated 31/05/1966, and 12/07/1966 mentioned in Schedules a and b and verbatim:schedule a rajasthan VANASPATI PRODUCTS PRIVATE LIMITED. RAW MATERIALS no. Tax/f. 139 (1)DLB/58 Jaipur, dated 31/05/1966. In exercise of the powers conferred under sub-section (5) of Section 107 of the Rajasthan Muncipalities Act,1959 (Act No. 38 of 1959), the State Govt. being of the opinion that reasonable grounds exist for doing so, hereby grants exemption to Rajasthan Vanaspati Products Private Ltd. , Bhilwara from payment of Octroi duty on the following raw materials imported from outside Bhilwara for a period of 10 years or till a policy decision is taken by the Govt. on the report of the High Power Committee, whichever is earlier, from the date of issue of this Notification in the Rajasthan Rajpatra. raw MATERIALS 1. Raw Materials:-ground nut, Cotton seed, Til Seed, Copra and oils and. oil cakes thereof required for manufacture of products. 2. Chemicals caustic Soda, Nickel Formate, Nickel, Catalyst, Fullers Earth, Hyflow Supercell, Salt common Citric, Acid, Soda Ash, Sodium Sillicate, Sulphuric acid, Hyd