JUDGMENT Gopalan Nambiyar, C.J. 1. These two writ Petitions attack the levy of water tax at different rates in the three different areas which now form the Cochin Corporation, and which were formerly administered by three separate Municipalities of Mattancherry, Ernakulam and Fort Cochin. The rates stood highest in the area served by the Mattancherry Municipality, namely, Rs. 8 per 1000 gallons; and lowest, we are informed, in the areas served by the Ernakulam Municipality, namely, Rs. 3 per 1,000 gallons. It was stated that the rate prevalent in the Fort Cochin Municipality was some what midway between these two; the exact figure was not stated. The Cochin Corporation was formed on 1st November 1967 by integration of the areas served by the three Municipalities. On and from 1st April 1972 uniform rates of water tax at Rs. 8 per 1,000 gallons, namely, the rate which prevailed in the Mattancherry Municipality, was adopted as the rate for the Cochin Corporation. The challenge in these writ Petitions is in respect of certain demands made on the Petitioners in respect of the period anterior to the unification, for which proceedings were threatened against the Petitioners. 2. The contention on behalf of the Petitioners was that the levy at differential rates in the different areas under the same Corporation is discriminatory and violative of Article 14. The answer made is that the differential rates of levy is justified on the ground of geographical classification based on historical reasons. Reliance for this purpose is placed on the decisions in Jia Lal v. Delhi Administration A.I.R. 1962 S.C. 1781 at 1784 State of Madhya Pradesh v. Bhopal Sugar Industries : A.I.R. 1964 S.C. 1179 Lachhman Dass v. State of Punjab 1962 : A.I.R. 1963 S.C. 222; Ram Prashad v. State of Punjab A.I.R. 1966 S.C. 1607 and a number of other cases. These decisions support the proposition in the form stated by counsel for the Corporation. But counsel for the Petitioners argued that the geographical classification for historical reasons must further satisfy the test that the classification had a relation or nexus to the object of the legislation, or, in this case, of the levy. Counsel for the Corporation demurred, and submitted this was unnecessary. Even positing this additional ingredient to be necessary, we think it is satisfied in this case. Counsel for the Corporation demurred, and submitted this was unnecessary. Even positing this additional ingredient to be necessary, we think it is satisfied in this case. The differential rates of taxation in the different areas can well be related to the different needs and requirements of the different Municipalities. As observed by the Supreme Court in the liberty Cinema's case A.I.R. 1965 S.C. 1107 para 27 at p. 1118. "It seems to us that there are various decisions of this Court which support the proposition that for a statutory provision for raising revenue for the purposes of the delegates, as the section now under consideration is, the needs of the taxing body for carrying out its functions under the statute for which alone the taxing power was conferred on it, may afford sufficient guidance to make the power to fix the rate of tax valid. We proceed now to refer to these cases." After examination of the cases the Supreme Court sustained the proposition and concluded as follows: "In the case of a self-governing body with taxing powers, a large amount of flexibility in the guidance to be provided for the exercise of that power must exist. It is hardly necessary to point out that, as in the cases under Essential Supplies (Temporary Powers) Act, 1946, so in the case of a big municipality like that of Calcutta, its needs would depend on various and changing circumstances. There are epidemics, influx of refugees, labour strikes, new amenities to be provided for, such as hospitals, schools - and various other such things may be mentioned, - which make it necessary for a colossal Municipal Corporation like that of Calcutta to have a large amount of flexibility in its taxing powers. These considerations lead us to the view that Section 548 is valid legislation. There is sufficient guidance in the Act as to how the rate of the levy is to be fixed." In the light of these principles we are of the opinion that the differential rates of levy satisfy even the test - if it were necessary to do so - of a rational nexus to the object of the levy. 3. We see no ground to sustain the plea of discrimination. We dismiss these Original Petitions with no order as to costs.