JUDGMENT : ( 1. ) THIS is petition under Articles 226 and 227 of the constitution of India for quashing the orders of the authorities under the property tax Act, 1964, described in details as M. P. Nagariya Sthawar Sampatti Kar adhiniyam, 1964, demanding property tax from the petitioner on the annual letting value of residential quarters made available to the members of the staff, valued at Rs. 34,980/- in respect of the assessment years, 1964-65, 1965-66 and 1966-67. ( 2. ) ACCORDING to the taxing authorities, the Board of Governors of the college would be liable to pay property tax in respect of houses made available to the members of the staff as that purpose cannot be said to be educational purpose. On the other hand, the contention of the petitioner is that the purpose would undoubtedly be an educational purpose as the members of the staff are required to live within the College premises and this is exclusively residential College and as such, the presence of the members of the staff for all the time is necessary. ( 3. ) THE property Tax Officer, by order, dated 31-8-1967 (Petitioners annexure-) decided the case against the petitioners contentions and imposed the property tax of Rs. 2529. 14 Ps. on the annual letting value of rs. 36,141. 98 paise. Against that order appeals were unsuccessfully filed before the Assistant Property Tax Commissioner and the Deputy Property Tax Commissioner, who, by orders, dated 24-1-1968 (petitioners Annexure-B) and dated 1-5-1970 (Petitioners Annexure-No. G) respectively affirmed the order of the property Tax Officer. ( 4. ) THIS case involves short point as to the interpretation of Section 6 of the M. P. Nagariya Sthawar Sampatti Kar Adhiniyam, 1964, i. e. the m P. Urban Immoveable property Tax Act, 1964. Section 6 of the Act relates to exemptions. We may reproduce sub-section (d) of the said section, which is as follows :- "section 6-Exemption-The tax shall not be leviable in respect of the following properties, namely:- ( ). . . . . . . . (b ). . . . . . . . . . (c ). . . . . . . . . . . . . . . . . . . (b ). . . . . . . . . . (c ). . . . . . . . . . . . (d) - buildings and lands or portions thereof used exclusively for educational purposes including schools, boarding houses, hostels and libraries if such buildings and lands or portions thereof are either owned by the educational institutions concerned or have been placed at the disposal of such educational institutions without payment of rent :" ( 5. ) THE question, therefore, arises whether in respect of the buildings which are used for accommodating members of the staff, such accommodation can be said to be for a non-educational purpose. We do not think that the word "educational purpose" has been used in a narrow sense. The phrase has been used in a wider sense and it will cover all activities connected with the educational institution. Such activities may consist of accommodation for the students, facilities for their Education, facilities for games or even providing accommodation to the members of the staff whose presence on the educational premises is necessary or even providing amenities and facilities to the members of the staff in respect of games and entertainments. We are clearly of the opinion that such activities which are properly connected with the educational institution or members of the staff can be said to be for educational purpose and the phrase, in our opinion, has been used in contra-distinction to any other purpose, such as a commercial purpose or any other purpose. ( 6. ) LOOKED at from that point of view, the interpretation put by the authorities functioning under the property Tax Act, 1964, cannot be sustained in law. Consequently, it is not necessary to consider the alternative case if the petitioner would be entitled to exemption under section 6 (f) (I) of the said act. We might have considered that provision if it had been so necessary. But in the view that we lake of section 6 (d) of the Act, we think it wholly unnecessary. ( 7. ) AS a result of the discussion aforesaid, the orders impugned cannot at all be sustained in law and, in our opinion, the buildings owned by the College were exempt from property tax altogether, as they were being used for an educational purpose. ( 7. ) AS a result of the discussion aforesaid, the orders impugned cannot at all be sustained in law and, in our opinion, the buildings owned by the College were exempt from property tax altogether, as they were being used for an educational purpose. Consequently, the said orders making a demand for property tax are quashed. But, however, as it involved a question of interpretation of the Section, we do not think it proper to award any costs. The outstanding amount of the security deposit be refunded to the petitioner. Petition allowed.