JUDGMENT

Walsh, J. - In this case the Sessions Judge of Allahabad has referred to this Court an order of the first class Magistrate which came before him by way of revision. As the first class Magistrate says, this is really a test case to decide how certain vehicles should be taxed. The complaint was made by the Municipal Board against Mr. G. Banerji of Canning Road for using a bicycle with a motor-wheel attachment without a license. The question is one of taxation and, as the Sessions Judge rightly says in his order of reference, enactments which render the public liable to pay taxes or charges of this nature must be construed strictly; or in other words, unless the language under which they are sought to be charged is perfectly clear, the charging authorities are not entitled to assess a charge inasmuch as the public have a right to know what exactly are the charges imposed upon them. Now in this case there are three classes of vehicles which are material (1) a motor car, (2) a motor bicycle, (3) a bicycle. The vehicle in question is of modern invention, that is to say, it is an ordinary bicycle with a motor-wheel which may be affixed to or detached from the bicycle itself as the