JUDGMENT : ( 1. ) THE question referred by the Tribunal under section 44 (1) of the M. P. General Sales Tax Act 1958 (hereinafter referred to as the Act) for decision by this Court is the following:- "whether Phawdas is covered under hoe (all kinds) in entry No. 1 of Separate Revenue Department Notification No. 736-3694/v/sr dated 1-4-1959 and as such is an agricultural implement and is, therefore, exempt from sales tax under entry No. 1 of Schedule I of m. P. General Sales Tax Act, 1958 ?" ( 2. ) THE matter first came up before a Division Bench of this Court but in view of the earlier conflicting decisions by different Division Benches of this Court, the case was referred to a Full Bench and this is how it comes before us. However, subsequent to the order requiring this case to be heard by a Full Bench, the very same question referred for decision by a Full Bench in another case came up for hearing and that decision of the Full Bench is in commissioner of Sales Tax, M. P. v. M/s. Narang Industries, Indore ( 1971 MPLJ 403 .) The question referred and the answer of the Full Bench in that case are as follows: -Question- "whether Phawdas are covered by item No. 1 of Separate Revenue Department Notification No. 736/3694/v. S. R. dated 1-4-59 and are exempt in serial No. 1 in Schedule I to the M. P. General Sales Tax Act, 1958 ?" Answer:- "phawadas that are not spades and shovels fall within the description of hoes (all kinds) and are covered by Item No. 1 of Separate Revenue Department notification No. 736-3694/v. S. R. dated 1-4-1959 and are exempt from tax under Serial No. 1 Schedule I to the Madhya Pradesh General Sales Tax Act, 1958. " ( 3. ) SHRI P. L. Mehta, the learned Additional Government Advocate appearing for the Revenue urged before us that the aforesaid Full Bench decision requires reconsideration on the ground that the authorised Hindi translation of the Government notification was not taken into account in that decision. Shri Mehta argues that the Hindi translation of the notification shows that the conclusion reached by the earlier Full Bench is incorrect. ( 4. Shri Mehta argues that the Hindi translation of the notification shows that the conclusion reached by the earlier Full Bench is incorrect. ( 4. ) WE shall confine ourselves to the only argument of Shri Mehta, since the same was apparently not advanced before the earlier Full Bench on account of which no occasion arose to consider the same then. So far as the arguments covered by the earlier Full Bench are concerned, we are in Full agreement with the view taken therein and as such there is no need to reiterate the same herein. ( 5. ) THE relevant facts are these:-The assessee M/s. Indore Iron Traders, Indore, manufacturer of iron implements, claimed exemption from payment of sales tax in respect of sale of Phawdas of the value of Rs. 53,300/- during the period from 1-4-1959 to 31-12-1959. The exemption it claimed by virtue of Entry No. 1 in Schedule I to the Act read with Separate Revenue Department Notification no. 736-3694/v. S. R. dated 1 6-1959. The Sales Tax Officer rejected the assessees claim for exemption while making the assessment by an order dated 11-5-1963. The first appeal to the Appellate Assistant Commissioner, sales Tax, Indore was also dismissed by Order dated 19-11-1963. The assessee preferred a second appeal to the Tribunal, which having succeeded, the present reference is made to this Court at the instance of the Department. The authorised Hindi translation of the notification having been published by the State Government prior to the decision of the assessees second appeal, the contention on its basis advanced by the Department before the Tribunal was also considered and negatived by the Tribunal. ( 6. ) ITEM No. 1 in the aforesaid Government notification dated 1-4-59 issued in English only is as follows :-"hoes (all kinds)" the Hindi translation of the above notification was published vide notification no. 685-V-Vi. Ka dated 29-2-1964 published in Madhya Pradesh Gazette, part I dated 15-5-1964 at page 968 for general information. According to this translation the corresponding item No. 1 in Hindi reads as follows :- It is significant to notice that the relevant notification was issued only in english and what was published in 1964 was only a translation thereof and not a fresh notification. According to this translation the corresponding item No. 1 in Hindi reads as follows :- It is significant to notice that the relevant notification was issued only in english and what was published in 1964 was only a translation thereof and not a fresh notification. For this reason the translation in Hindi is relied on only as an aid to construction of the English notification dated 1-4-59 by which really the exemption was granted and which alone was available at the time when liability to pay tax arose. Since we have reached the conclusion that there is no inconsistency between the notification in English and its translation in Hindi issued much later, we do not decide whether such an external aid to construction is really available and we proceed on the assumption that it can be looked into for this purpose. ( 7. ) THE argument of Shri Mehta really is that the word "kudhali" cannot be construed to include within the its ambit Phawada so that after publication of the Hindi translation, the conclusion reached by the earlier Full Bench cannot be supported even conceding that the word "hoe" includes within its ambit Phawada as held by the earlier Full Bench. Shri Mehta argues that "kudhali" is in fact an implement with a narrow and thick block of metal having a sharp edge at the end fitted to a wooden handle, whereas Phawada, consists of a this flat blade, which is much wider, Shri Mehta also argues that by the word "kudhali is meant only such an implement and none else, the Kudhali being used for digging the earth deeper. Shri Mehta is, however, unable to suggest any reason whatsoever why the words" should have been used, if Kudhali can mean only one implement of one type alone as argued by him. ( 8. ) IT is not doubted that Phawadas that are not spades and shovels fall within the description of hoes (all kinds) as held by the earlier Full Bench for the reasons given in that decision. The only surviving question before us now is whether the same conclusion can be reached with reference to the Hindi translation, assuming that the translation made by the State Government can be looked into for this purpose. The only surviving question before us now is whether the same conclusion can be reached with reference to the Hindi translation, assuming that the translation made by the State Government can be looked into for this purpose. As already pointed out, it is not a case wherein a notification using the word "kudhali" in Hindi has to be construed, the question being really to construe the notification issued in English. The Hindi rendering of the notification is, therefore, only a translation made subsequently of the English notification, wherein there could be no occasion to alter the meaning of the words used in the initial notification issued only in English. For this reason we shall refer to the meaning of the word "kudhali" given in the various dictionaries. ( 9. ) SINCE the translation was made from English to Hindi, it is reasonable to infer that some dictionary from English to Hindi must have been used for this, purpose. References is, therefore, made first to the meaning given in the dictionaries from English to Hindi. In Bhargavas Standard Illustrated Dictionary of the English Language (Anglo-Hindi), the meaning of "hoe" is given as as synonyms. The third includes belcha as one of the meanings which is a type of Phawada, in addition to other meanings. The fourth given even in the last dictionary to exclude a Phawada as one of the meanings. ( 10. ) WE shall now refer to the dictionaries from Hindi to Hindi. In Vrihat Hindi Kosh (Third Edition) published by Gyan Mandal Limited, Varanasi, the meaning of Thus, the Hindi equivalent of phawada is given in this dictionary as a kudali of wider blade. In other words, the two meanings read together necessarily show that Kudali and Phawada are synonyms describing impliments of the same type or category, the only difference being that the blade is wider in a Phawada and narrower in Kudali. ( 11. ) IN Bhargavas Standard Illustrated Dictionary of the Hindi language (Hindi-English Edition) which is obviously a companion volume of the aforesaid English to Hindi Dictionary by the same author referred to above, the English rendering of Kudal is "a hoe, a pickaxe, a spade, shovel, etc. ". ( 11. ) IN Bhargavas Standard Illustrated Dictionary of the Hindi language (Hindi-English Edition) which is obviously a companion volume of the aforesaid English to Hindi Dictionary by the same author referred to above, the English rendering of Kudal is "a hoe, a pickaxe, a spade, shovel, etc. ". Reading together the equivalents given in these two dictionaries by the same author, it is clear that the word "kudal" or "kudali" is of wide import including within its ambit a hoe, and that Kudali and Phawada are synonyms. ( 12. ) THUS, the net result arrived at on the basis of the aforesaid dictionary equivalents is that the word "kudali" is used in the Hindi translation of the notification in a generic sense to also include an agricultural implement called phawada which is included within the meaning of the word hoe used in the english notification. Such an intention is manifest also from use of the words which clearly suggests that the expression is of wide import covering all kinds of implements of that type. ( 13. ) THE above conclusion is also supported by the fact that item No. 2 in the above notification is "pickaxes (all kinds)", which is translated into Hindi in the aforesaid Hindi version as Items Nos. 1 and 2 of the notification read together were apparently intended to include all the agricultural implements operated manually and used for loosening the soil, whatever be their shape. ( 14. ) IN our opinion, the translation in Hindi of hoe as kudali was neither intended to nor did it have the effect of narrowing down the meaning of the word hoe used in the notification itself issued earlier in English. Just as the expression "hoes (all kinds)" is wide enough to include Phawadas other than those which are spades or shovels, the expression in Hindi is similarly wide enough to include such Phawadas which have been held to fall within the description of "hoes (all kinds ). " ( 15. ) WE are, therefore, of the opinion that there is no merit in the argument advanced in the present case by Shri Mehta and it does not have the effect of doubting the correctness of the decision given by the earlier Full bench. In fact, viewed at even from this angle, the conclusion is the same. " ( 15. ) WE are, therefore, of the opinion that there is no merit in the argument advanced in the present case by Shri Mehta and it does not have the effect of doubting the correctness of the decision given by the earlier Full bench. In fact, viewed at even from this angle, the conclusion is the same. As already stated, we have not reiterated the other reasons in support of this conclusion which are stated in the earlier Full Bench decision in Commissioner of sales Tax, M. P. v. M/s Narang Industries, Indore (supra ). With respect we are in full (agreement ). ( 16. ) THE result is that our answer to the above question is the same as that of the earlier Full Bench as follows :- "phawadas that are not spades and shovels fall within the description of hoes (all kinds) and are covered by Item No. I of Separate Revenue Department Notification No. 736-3694-V. S. R. dated 1-4-1959 and are exempt from tax under Serial No. 1 Schedule I to the M. P. General Sales Tax Act, 1958. " ( 17. ) THE reference is answered accordingly, The parties shall bear their own costs. Reference answered.