ORDER Dixit, C.J. In this petition under Articles 226 and 227 of the Constitution of India the question raised is as to the liability of the opponent No. 3 to pay octroi duty on kerosene oil imported within the Municipal limits of Bhatapara and stocked in tanks constructed by the oil distributing companies in railway area. According to the petitioner Municipality, it has been levying since the 4th November 1949 octroi tax, under section 66 (1) (e) of the C. P. and Berar Municipalities Act, 1922, on all animals and goods including kerosene brought within the municipal limits for sale, consumption or use. Under the bye-laws framed by the committee for the assessment, collection and refund of the octroi tax (published in Madhya Pradesh Gazette, Part-Ill, dated the 4th November 1949, at page 1140), articles subject to octroi duty become liable to duty as soon as they enter the octroi limits. In regard to goods imported by railway, bye-laws Nos. 17 and 18 provide as follows :- Goods imported by Railway.-An outpost with an assistant superintendent or inspector in superior charge shall be maintained near the Railway station. Goods arriving by railway shall be deemed to have entered the octroi limits directly they pass out of the railway station enclosures and shall be dealt with in the manner prescribed in these rules. The opponent No. 3 firm Moujiram Murarilal imports within the municipal limits kerosene oil from Burmab Shell and Stanvao. The oil is brought by rail in oil tank wagons. The railway wagons containing the oil on their arrival at Bhatapara station are taken on a loop line and then the oil contained in the wagons is transferred by a pipe-line to the oil tanks constructed by the oil distributing companies within the railway boundary. The opponent No. 3 has its depot very near these oil tanks and from there the firm carries on business of retail and wholesale sale of the oil. The committee claimed that octroi duty was payable by the opponent No. 3 on each consignment at the time when it is unloaded and the oil is transferred into the oil tanks belonging to the companies. To this the opponent No. 3 demurred and contended that under bye-law No. 18 no octroi duty was payable on kerosene so long as it was within the railway limits. To this the opponent No. 3 demurred and contended that under bye-law No. 18 no octroi duty was payable on kerosene so long as it was within the railway limits. When the municipal committee made a demand for payment of tax on the consignments of kerosene received by the opponent-firm on the 16th November 1957 and the 19th December 1957, the firm, without making any payment of tax, served a notice on the municipal committee and thereafter filed an appeal before the Sub-divisional Officer. The Sub-divisional Officer held that no tax was payable until kerosene passed out of the railway boundary as contemplated by bye-law No. 18. The Sub-divisional Officer made an order restraining the committee from recovering octroi tax on kerosene and other articles lying within the railway-yard fencing and to refund octroi duty levied on goods thus stocked. The committee then preferred a revision petition before the Board of Revenue, which was dismissed. Hence this petition. On a reading of section 66 (1) (e) of the Act and the byelaws framed by the Municipal Committee for the assessment and collection of the tax, it is clear that though goods become liable to payment of octroi duty when they are brought within the municipal limits for consumption or use within those limits, liability to the actual payment of tax does not arise until the goods are brought within the octroi limits. Now, so far as goods imported by raid are concerned, bye-law No. 18 provides that the goods shall be deemed to enter the octroi limits directly they pass out of the railway station enclosures. It is plain enough from the wording of this bye-law that so long as the goods are within the railway station enclosures, they are regarded as outside the octroi limits and the importer does not become liable to pay octroi tax on goods remaining within the railway station enclosures. His liability arises only when they pass out of the railway station enclosures. The question then arises as to the meaning of the expression "railway station enclosures". His liability arises only when they pass out of the railway station enclosures. The question then arises as to the meaning of the expression "railway station enclosures". Shri Sen, learned counsel for the applicant, argued that 'railway station enclosures' mean only railway platform, station yard and goods shed; and that the oil-tacks constructed by the oil companies, though located within the railway boundary, cannot be regarded as within the railway station enclosures, and that, therefore, the moment the oil is transferred from the railway wagons to these tanks, the opponent-firm becomes liable to octroi tax on kerosene stocked in those tanks. Reliance was placed on South Eastern Bail. Co. v. Railway Commissioners etc. (1). We are unable to accede to the contention of the learned counsel for the applicant. The plain meaning of the words "railway station enclosures" is all that land which is used for the purpose of railway station, that is to say, the whole of the railway area in which railway platform, structures, station yards, goods shed, and the oil tanks in question are admittedly situated. The decision in South Eastern Bail. Co. v. Railway Commissioners etc. (1881) 50 LJR 201 is not of any assistance here. In that case the question was whether the Railway Commissioners had on a complaint made to them under section 3 of the Railway and Canal Traffic Act (17 and 18 Vict. c. 31) jurisdiction to make an order requiring the railway company to enlarge the station, to provide better booking office, and waiting room, to enlarge platform and to provide a new road of approach to cover over the bridge, and make other alterations. c. 31) jurisdiction to make an order requiring the railway company to enlarge the station, to provide better booking office, and waiting room, to enlarge platform and to provide a new road of approach to cover over the bridge, and make other alterations. In connection with that question, it was held that the terms "railway" and "railway station" as used in the relevant statute should be construed not as merely legal terms but as "descriptions in ordinary phraseology of well understood things of an ordinary kind"; tad that the term 'station' is not in ordinary sense used as a "description merely of the existing structures at a station bat as the description of a apace actually set apart for and generally used as a resting place for traffic, or a place for dealing with it in a particular way, although every part of the space is not covered with structures or used for passing along or for deposit." In that ease there was no question of the construction of the word 'enclosures' used in relation to railway station. Indeed the description of the word "station" given in the ease is so wide that on that description if a space is set apart for railway purposes and is within the railway station enclosure, then a part of the space would not cease to be within the railway station enclosure merely because oil tanks, not constructed by the railway but by the oil distributing companies for the facility of transfer of oil from railway wagons to the tanks and for storage therein, are located there. In our opinion, the Board of Revenue was right in holding that the opponent-firm was not liable to pay any octroi duty on kerosene so long as it was stored in the tanks situated within the railway boundary. This petition is, therefore, dismissed. There will be no order as to costs. The outstanding amount of security shall be refunded to the petitioner. Petition dismissed