K.K. Sasidharan, J.

Being aggrieved by the order of the learned Single Judge dated 210. 2003 in W.P.No.1993/1997 confirming the proceedings of the Regional Transport Officer taxing the motorcycles as commercial vehicles, the unsuccessful Writ Petitioner has preferred this appeal.

Background facts :-

2.The appellant is the owner of a driving school at Namakkal. The appellant is also the owner of two motorcycles bearing nos. TDW 8425 (Scooter) and TAL 4805 (Moped without gear). Both these vehicles were registered in the name of the appellant for personal use. The appellant used those two motorcycles for the purpose of the driving school which made the Regional Transport Officer, Namakkal to pass the order dated 010. 1996 directing the appellant to pay vehicle tax for the two motorcycles treating the same as commercial vehicles. The appellant was directed to pay tax under the caption "others" as per clause 7 of the Tamil Nadu Motor Vehicles Taxation Act, 1974. The said proceeding was challenged by the appellant in W.P.No.1993/1997.

3.Before the learned Single Judge, it was the contention of the appellant that the two motorcycles registered in his personal name were used for i