JUDGMENT

M.H. Beg, J. - These are seven connected writ petitions in each of which the petitioner is a partnership firm which is registered and licensed as a dealer under Section 3-E of the U.P. Sales' Tax Act (hereinafter referred to as 'the Act') . Each petitioner is a dealer in food grains purchasing large quantities of pulses from Dal manufacturers every year. The manufacturers are alleged to have purchased these as 'unbroken seeds' and converted them into Dal, by putting them through a process which is described as 'manufacture', before selling it to petitioners. According to the petitioners, the process through which the unbroken seeds were put by the manufacturers did not involve a change in the chemical composition or the commercial character of the produce but put the pulses into a state fit for consumption by braking up the seeds and cleaning the raw product. The petitioners allege that they are, therefore, not first purchasers of Dal liable to pay purchase tax. Each petitioner has also questioned the constitutional validity of Section 3-D of the U.P. Sales Tax Act as well as of the exercise of the powers vested in the State Government in issuing the notifications against f