JUDGMENT P. Govindan Nair, C.J. 1. These appeals are against the common judgment disposing of Original Petition Nos. 3343 and 4305 of 1973. The question that arose for consideration was whether the petitioners in the Original Petitions are liable to be taxed under the Kerala Motor Vehicles (Taxation of Passengers and Goods) Act, 1963, for short, the 1963 Act. The learned Judge in the judgment under appeal held that the petitioners in the Original Petitions were not liable to be taxed with reference to the vehicles concerned, and thus allowed the Original Petitions. 2. The relevant facts are stated in paragraphs 2 and 3 of the affidavit in support of the Original Petition in O.P. No. 3343 of 1973 which have been adverted to by the learned Judge which we may also extract: "The Petitioner Company is carrying on the business of tea planting in India in Peermade Taluk. The petitioner owns a number of tea estates in and around Vandiperiyar. For the purpose of transporting the green tea leaves from the fields to the factory, for the purpose of the conveying fungicides, insecticides, fertilisers, etc., to the fields and other ancillary purposes the petitioner uses trailers. The said trailers are drawn or hauled by agricultural tractors of Massey Ferguson or Eicher types. The said tractors are standard agricultural machines, with a draw bar for attaching, disc or rake plows, or other agricultural equipment like threshers, harvesters etc. The tractors are also provided with a power take off shaft for connecting winches, generators or pumps. For hauling the trailer the tractor is provided with a hook, at the rear below the power take off shaft to which the hitch beam of the trailer can be attached. 3. By its very construction the said tractors of the petitioner are not capable of carrying or conveying any goods or passengers, but is only capable of providing the traction or motive power for various purposes. The petitioner tractors are used as locomotives for hauling trailers. A photograph of one of the tractors belonging to the petitioner is filed herewith and marked Exhibit P-1.� 3. The 2nd appellant who was the 2nd respondent in the Original Petition relied on the following averments in paragraph 5 of the counter-affidavit: The tractors are used for hauling trailers and the trailers are used for transporting goods. A photograph of one of the tractors belonging to the petitioner is filed herewith and marked Exhibit P-1.� 3. The 2nd appellant who was the 2nd respondent in the Original Petition relied on the following averments in paragraph 5 of the counter-affidavit: The tractors are used for hauling trailers and the trailers are used for transporting goods. Tractor-trailer combinations or articulated vehicles, are vehicles adapted for the carriage of goods. It is goods vehicle for the purpose of the Act in question. The combination will come within the purview of section 2(8) and (18) of the M.V. Act. The vehicles of the petitioner will be ˜goods vehicles within the meaning of the term in the Kerala Motor Vehicles (T.P.C.) Act, 1963, since the tractor-trailer combinations are adapted for the carriage of goods and are admittedly used as such by the petitioner."� 4. We may also refer to paragraph 11 of the counter affidavit of the 2nd respondent and paragraph 3 of the additional counter-affidavit filed by the same respondent. Those are in these terms: "11. When a tractor only is registered, a registration mark is given to it. So also when a trailer alone is registered. But when a tractor together with a trailer is registered, as an articulated vehicle the combination is assigned on registration mark."� ****** "By attaching trailers to the tractors, the petitioner is adapting the vehicles for carrying goods. The adaptation done by the petitioner is a sufficient physical alteration for the purpose of attracting the tax liability."� 5. The provisions in the 1963 Act with which we are concerned are mainly those contained in section 2(a) defining 'good vehicle' and the charging section, section 3(1). We shall extract those sections: (a) goods vehicle means any motor vehicle constructed or adapted for use for the carriage of goods, or any motor vehicle not so constructed or adapted when used for the carriage of goods solely or in addition to passengers;� * * * * "3. We shall extract those sections: (a) goods vehicle means any motor vehicle constructed or adapted for use for the carriage of goods, or any motor vehicle not so constructed or adapted when used for the carriage of goods solely or in addition to passengers;� * * * * "3. Levy of tax on passengers and goods: - (1) On and from the date of commencement of this Act, there shall be levied and paid to the Government a tax on all passengers, luggage and goods carried by stage carriages and on all goods transported by goods vehicles, at the following rates, namely:- (a) in the case of stage carriages, 10 paise in the rupee, on the fares and freights payable to the operators of such carriages; (b) in the case of public carrier vehicles, five paise in the rupee on the freights payable to the operators of such vehicles; (c) in the case of private carrier vehicles, 2 paise per tonne kilometre of the goods."� 6. The 1963 Act does not define a "motor vehicle"� nor does it define a 'tractor' or a 'trailer. The Motor Vehicles Act, 1939 (Central Act 4 of 1939) defines all the three expressions and the Kerala Motor Vehicles Taxation Act, 1963 by virtue of section 2(1) has incorporated the definitions in the Central Act for the purpose of the Kerala Motor Vehicles Taxation Act, 1963. 7. The question considered by the learned Judge which again arises before us is whether the tractor-trailer combination in question can be said to be a 'goods vehicle' constructed or adapted for the use of carriage of goods or if it had not been so constructed or adapted, it has been used solely for the carriage of goods or for the carriage of goods in addition to passengers. The tractor apart from its description is evidenced by a photograph of it, which is Ext. P-1 produced in O.P. No. 3343 of 1973. The trailer had been attached to the tractor and goods were transported by the combination. The contention on behalf of the Revenue was that the tractor had been constructed and adapted for the carriage of goods and the two together can be taken to be a motor vehicle used for the carriage of goods and hence the tax liability under the 1963 Act has been attracted. 8. The contention on behalf of the Revenue was that the tractor had been constructed and adapted for the carriage of goods and the two together can be taken to be a motor vehicle used for the carriage of goods and hence the tax liability under the 1963 Act has been attracted. 8. A number of decisions, English and Indian had been cited before us, dealing with various enactments and the definitions and expressions therein. While these decisions throw some light generally on the question that arises here, we do not consider that they are of great persuasive value and are of great help in deciding the particular question before us. We shall therefore examine section 2 (a) containing the definition of 'goods vehicle' which we have extracted above. A careful reading of the section indicates the following aspects. The construction or adaptation envisaged by the section must be to the motor vehicle, for the expression is "motor vehicle constructed or adapted". The only construction relied on is the existence of the hook in the tractor to which the trailer is attached. Though this hook can be said to be a construction whether the hook as such will be a construction for use for carriage of goods is doubtful unless we give to the word carriage the meaning of "hauling" as well. This aspect we will deal with presently but shall for the, moment proceed on the basis that the word 'carriage'� meant bearing and moving, or supporting and moving. If that is the meaning to be given to the word 'carriage' in the context in which it occurs in the section the hook that has been constructed in the tractor at the time of manufacture cannot be said to be a construction for the use of carriage of goods nor are we able to say that the tractor has been adapted for the use of the carriage of goods. The word adapted in the section has to be understood by reading the definition as a whole. So read adaptation, in the sense of a physical change must be made to the vehicle; in the case before us to the tractor. This discussion is of course on the basis that the tractor is a motor vehicle as has been stated in the decision of this court in State of Kerala and others v. Jacob Jose , 1971 K.L.J. 34. This discussion is of course on the basis that the tractor is a motor vehicle as has been stated in the decision of this court in State of Kerala and others v. Jacob Jose , 1971 K.L.J. 34. Even so, the attachment of a trailer to the tractor cannot be said to be an adaptation of the tractor for use for carriage of goods. The only way therefore of bringing the combination of the tractor and the trailer within the section would be to understand the combination as a single vehicle and to so treat the combination is difficult. In this connection we must remember that not only in common parlance and in accordance with the normal understanding of the common people, but even in the statutes, the Central Act as well as the Vehicles Taxation Act, tractor and trailer have been separately defined and understood as two separate and distinct vehicles. We must also refer to the definition of the term 'articulated vehicles'� occurring in section 2 (1A) of the Central Act. 'Articulated vehicle' means a tractor to which a trailer is attached in such a manner that a part of the trailer is super-imposed on, and a part of the weight of the trailer is borne by, the tractor. No such thing has admittedly happened in this case and it will therefore be difficult to understand the tractor-trailer combination as a single vehicle though the two together can be utilised for carriage of goods. But in order to satisfy the definition of a goods vehicle one must be able to conceive of a single vehicle, a motor vehicle constructed or adapted, or atleast constructed and adapted for the use for carriage of goods. It was contended that the word 'for use' occurring between the words 'adapted' and for� would give a wider meaning to the definition. We do not think so, for, the words for use, as we see it qualify constructed or adapted. The construction or adaptation must be for use in a particular manner, namely, for carriage of goods and that construction or adaptation must be of the vehicle, which we are considering in these cases, a tractor. We do not think so, for, the words for use, as we see it qualify constructed or adapted. The construction or adaptation must be for use in a particular manner, namely, for carriage of goods and that construction or adaptation must be of the vehicle, which we are considering in these cases, a tractor. From what we have said above, the conclusion seems to be inevitable applying to the word carriage the meaning bearing and moving that, the tractor-trailer combination cannot be said to be a goods vehicle within the meaning of that expression in section 2(a) of the 1963 Act. 9. Much arguments turned on the question as to what is meant by carrying. Carrying no doubt will comprehend conveyance. But conveyance need not always be by carrying. The ordinary meaning of the word carrying appears to us to be supporting and moving. When a suit-case is placed in the luggage booth of a car and taken from place to place one can legitimately say that the car was used for the carriage, of the suit-case. But if the suit-case is kept in a trailer attached to the car and taken from place to place we think it would be incorrect to say that the car was constructed or adapted for use for the carriage of the suit-case. The Road Traffic Act, 1960 has obviated this difficulty by specifically including hauling within the expression carriage of goods� in section 191(1) which is in these terms:” "191.-(1) In this part of this Act and the Thirteenth and Fourteenth Schedules thereto, unless the context otherwise requires, the following expressions have the meanings hereby assigned to them respectively, that is to say," * * * * Carriage of goods includes the haulage of goods; * * * *� In the absence of any such expression in the definition with which we are concerned we must understand the section as only intending to define vehicles which by themselves bear the load and convey the goods from place to place. 10. 10. Reference was made to the expression "all goods transported"� occurring in the last part of section 3(1) and it was submitted that if the carriage has got a limited meaning the transport is wide enough to take haulage and that therefore the charging section read with the definition section clearly spells out that combinations such as the one we have will be liable for tax under the 1963 Act. This argument fails to note that the goods transported must be by goods vehicles. Unless we are able to accept the contention that the tractor-trailer combination is a goods vehicle, this argument has no force. We have already indicated that we find it difficult to accept the argument that a tractor-trailer combination is a single vehicle and that when goods are conveyed by being hauled or by pulling the trailer there is carrying of the goods by the tractor. 11. In the view that we have taken, we dismiss these Writ Appeals. We make no direction regarding costs.