Janarthanam, J.

1. All these actions—this Batch of Writ Petitions-filed by Importers-Dealers or otherwise — of motor vehicles into local area from any place outside the State of Tamil Nadu for use or sale herein — owning motor vehicle at the time of its entry into the local area-are analogous in nature.

2. The thrust and focus either on pure questions of law — constitutional or otherwise or on facts the existence of which is a matter of proof — giving risk to legal figment are mostly common or similar.

3. Irrespective of the nomenclature of these actions — Writs — Whether for Declaration, mandamus. Prohibition and what not — the fact remains — constitutional questions revolving on :

.(i) Legislative competence ;

.(ii) Colourable piece of Legislation;

(iii) Violation of rights under Articles 301 and 304 of the Constitution of India (for short Constitution);

.(iv) Absence of prior approval of the President of India under the Proviso to Article 304

.(b) of the Constitution.;

.(v) Challenge on the ground of Articles 14 and 300-A of the Constitution: and allied matters therefor were raked up, apart from the applicability of the Legislation impugned to the factual matrix of the individual cases. Such being the case, we rather feel, better it is, they are dealt with and decided by a common Order with ease and grace and without any difficulty whatever.

4. The factual matrix giving rise to all these actions may, in brief, be related.

.(a) As of now, there is no manufacture of motor vehicles in the State of Tamil Nadu. Motor vehicles manufactured outside the State are imported into this State, either by Dealers or others, for sale or use herein. Motor Vehicles manufactured in a State, either by Dealers or others, for sale or use herein. Motor Vehicles manufacturers in a State are being sold by the manufacturers in the other States, more or less at the same price, except by adding to the price, the cost of transport, which may vary from St ate to state, depending upon the distance factor from the place of manufacture. However, the ultimate price or cost of such vehicles varies very widely to the dealer or consumer in a State as a consequence of imposition or levy of sales — tax and others taxes at different rates by different States. For instance, the imposition or levy of sales — tax on motor vehicles in the Union Territory of Pondicherry is at 4% whereas in the State of Tamil Nadu, it is 13%. Thus, there is a different in tax to the tune of 9%. Therefore, the costs of a motor vehicles purchased in the Union Territory of Pondicherry will be less by 9% that is to say, if the invoice price of a vehicle is Rs. 3 lakhs, there will be a difference in price to the tune of Rs. 27,000. Thus, the margin of difference in the ultimate price of the vehicle will vary, depending upon the rate of levy and collection of sales-tax on the invoice price of the vehicle. The rate of sales — tax on motor vehicles in certain other States, it is said, is comp aratively lesser than the rates charged in the State of Tamil Nadu.

.(b) This sort of situation impelled the dealers and consumers to the purchase of motor vehicles in the Union Territory of Pondicherry and in the other States as well where the tax structure is comparatively low. The concomitant consequence that flows from such a situation was that the State of Tamil Nadu suffered, in a large measure, loss of revenue, by way of sales tax on the sale of motor vehicles.

.(c) In order to compensate or off-set the loss so suffered the State of Tamil Nadu contemplated or devised a measure for imposition of Entry Tax on motor vehicles brought from outside and imported into this state, either by dealers or consumers for the purpose of sale or user herein which resulted in the passing of necessary and requisite Legislation in the year 1990, viz., The Tamil Nadu Tax on Entry of Motor Vehicles into Local Area Act, 1990 (Act XIII of 1990 for short ‘Principal Act’). The Legislation s o passed