Kapur, J.

1. These are four rules Issued against the Excise and Taxation Commissioner, Punjab, and another to show cause why a writ of mandamus should not issue against them. The petitioners in all these applications are different but the point raised is the same. The petitions are Writ Applications (Civil) Nos. 135 of 1953, 20 of 1953, 36 Of 1953 and 390 Of 1952.

2. The facts disclosed in each one of the petitions are that the petitioners are manufacturers of edible oils and are using electric power for crushing of oil from different kinds of seeds--sarson, toria & til. The petitioners in the various cases applied under Section 18, East Punjab General Sales Tax Act of 1948 as to their liability to pay sales tax tout in each one of the cases they weretold by the Excise and Taxation Commissioner, Punjab, by letter dated 6-2-1952

"that the intention of Government underlying the exemption contained in item 57 of the schedule appended to the Punjab General Sales Tax Act, 1948, is to exempt ghanis worked by human or animal power only and not by electric power."

3. In each one of these petitions the allegation is that the Excise and Taxation Commissioner, Punjab, or the officers