JUDGMENT :

A.K. JAYASANKARAN NAMBIAR, J.

1. These writ petitions bring to the fore the general and widespread aversion amongst our citizenry to taxes. Ingenious and varied are the submissions advanced before courts in their attempts to claim the benefit of exemption clauses that would insulate them from a levy. What is missed out often in these desperate attempts, is the general principle in taxation law that exemption provisions in a taxing statute, unlike the charging provisions therein, are interpreted strictly in favour of the revenue and against an assessee. A court hearing arguments challenging the constitutional validity of an exemption provision in a fiscal statute, strives to uphold its validity and it is only if it is impossible to do so that the provision is declared unconstitutional. The burden on those who assail the statutory provision is therefore quite heavy.

2. The petitioners in these writ petitions are self-financing educational institutions. They impugn the demand of property tax from them under Section 203 of the Kerala Panchayat Raj Act/Section 233 of the Kerala Municipality Act, 1994 [both Acts hereinafter together referred to as the ‘Acts’]. It is stated that a