Judgment

HEGDE, J. :- This appeal by certificate arises from the decision of the Allahabad High Court in Civil Misc. Writ No. 6424 of 1971. The appellants are brick manufacturers in the District of Lucknow. They are registered dealers under the U. P. Sales Tax Act, 1948 (to be hereinafter referred to as the Act). They challenge the assessment proceedings under the Act for the assessment years 1968-69, 1969-70, 1970-71 and 1971-72 and contest the validity of Section 3-AB of the Act which was incorporated into the Act by the U. P. Sales Tax (Amendment and Validation) Act, 1971 (No. 20 of 1971). They contest the validity of that provision on various grounds. The High Court rejected those contentions and dismissed the writ petition. Hence this appeal.

2. Though the question of law arising for decision in this case are fairly simple, this case has a long history. It is necessary to refer briefly to the struggle that went on between the State and the brick manufacturers, culminating in the enactment of the impugned provision, S. 3AB. The Act was enacted in 1948. Section 3 therein imposes multi-point sales tax on the sale of certain goods. Section 3-A was inserted in the Act in that very ye