Land revenue has acquired a definite meaning.

ISMAIL, C. J.:- This batch of writ petitions raises common questions regarding the validity of Section 52-A of the Tamil Nadu Revenue Recovery Act (I of 1864) as amended by the Tamil Nadu Act 12 of 1972, hereinafter referred to as the Act. The said Section 52-A reads as follows :-

"52-A. Recovery of sums due to the Tamil Nadu Agro-Industries Corporation and another. Corporations etc :-without prejudice to any other mode of recovery which is being taken or may be taken, all loans granted and all advances made to any person -

(i) by the Tamil Nadu Agro Industries Corporation Limited, Madras or

(ii) by such other Corporation (the shares of which have been contributed, underwritten or guaranteed by the State Government) as may be notified in this behalf by the State Government in the Tamil Nadu Government Gazette, or

(iii) from out of the Amalgamated Tamil Nadu Shares of the Post War Services Reconstruction Fund and the Special Fund for Reconstruction and Rehabilitation of Ex-servicemen, together with interest on such loans and advances, and all sums due to the Corporations mentioned in Clauses (i) and (ii) may be recovered in the same manner as arrears of land revenue under the provisions of this Act."

Pursuant to Section 52-A (ii) the Government of Tamil Nadu have from time to time issued notifications, notifying the Corporations such as the State Industries Promotion Corporation of Tamil Nadu Ltd. the Tamil Nadu Small Industries Development Corporation Ltd., the Tamil Nadu Industrial Investment Corporation Ltd., the Tamil Nadu Small Industries Corporation Ltd., the Tamil Nadu Textile Corporation Ltd., the Tamil Nadu Handicrafts Development Corporation, the Tamil Nadu Ceramics Ltd., the Tamil Nadu Handloom Finance and Trading Corporation Ltd., the Tamil Nadu Theatre Corporation Ltd., the Tamil Nadu Forest Plantation Corporation Ltd., the Tamil Nadu Tea Plantation Corporation, the Tamil Nadu Dairy Development Corporation, the Tamil Nadu Harijan Housing and Development Corporation, the Tamil Nadu Sugar Farm Corporation and others, as Corporations for the purpose of the said section. The petitioners in these cases have borrowed monies from some of these Corporations which have been impleaded as respondents in these writ petitions. For the purpose of recovering the amounts due from the petitioners to the said Corporations, proceedings were initiated under the Act and the Tahsildars concerned have issued notices calling upon the petitioners to pay the amounts and in certain cases, distraint orders have also been made.

2. The petitioners have come to this Court under Article 226 of the Constitution of India complaining against the said action on the ground that Sec. 52-A of the Act is itself ultra vires. According to the petitioners, the Tamil Nadu Legislature lacks competency to enact Section 52-A because none of the entries contained in List II or List III of the Seventh Schedule to the Constitution will cover the Section in question. Their further contention is that the said Section violates Article 14 of the Constitution, because it confers an unguided power on the State Government to notify any Corporation, provided its shares have been contributed, underwritten or guaranteed by the State Government, without declaring or disclosing any legislative policy in that behalf. Yet another contention of the petitioners also relates to Article 14 of the Constitution and according to them, the Legislature has treated unequals as equals in violation of Article 14. They also contend that with regard to the amounts payable by them to the respective Corporations, before the notification of the said Corporations under Section 52-A (ii) of the Act, the provisions of the Act cannot be set in motion.

3. As against this, the case of the State as well as the Corporations, as put forth in the counter-affidavits filed by them in the writ petitions, is that the law enacting Section 52-A into the Act falls within the Entry 45 of List II of the Seventh