( 1 ) WE have heard learned counsel for the petitioner on this petition under Article 226 of the constitution.

( 2 ) THE petitioner is a dealer in foodgrains, a commodity sales of which are liable to sales tax under Section 3 of the U. P. Sales Tax Act. By a notification issued on 30-9-1956 under sec. 4 of the U. P. Sales Tax Act, as amended from time to time, the State Government directed that the provisions of Section 3 of the said Act shall not apply to sale of foodgrains on certain conditions. The principal condition was that the dealer concerned must obtain an exemption certificate after paying fees laid down in that notification. The amount of fees payable depended on the amount of turnover of the dealer. It was first contended by learned counsel for the petitioner that this notification issued by the State government fell under the provisions of Clause (a) of Section 4 of the U. P. Sales Tax Act. In our opinion, this is not so. The notification does not exempt sales of foodgrains in general, as contemplated by Clause (a) of Section 4, of the said Act. What the notification does is to exempt sales of foodgrains by certain dealers, the dealers being those who o