JUDGMENT HARI LAL AGRAWAL, J. 1. The three petitioners in this writ application are challenging the notices issued to them on different dates by the Secretary of the Agricultural Produce Market Committee, Ranchi (Respondent No. 2), copies of which have been made Annexure 1, 1/a and l/b to this writ application, calling upon them to take out licences under the provisions of the Bihar Agricultural Produce Markets Act, 1960 (briefly the 'Act') as they were dealing in 'wool' one of the notified "agricultural produce" under the Act, on the ground that the commodity in which they dealt was not 'wool' but 'knitting wool' and entirely different commercial commodity. 2. Whereas the first two petitioners are the partners of the firm Messrs Wool Emporium and Wool House respectively, the third petitioner is the proprietor of Shandar Stores, all in the town of Ranchi. In order to appreciate the question raised for our consideration, I shall very briefly indicate the relevant provisions of the Act, and the Rules, namely, the Bihar Agricultural Produce Markets Rules, 1962, framed under the provisions of the Act, (briefly the 'Rules'. According to Rule 11, "no person shall do business as commission agent or trade in agricultural produce in a market except under a licence granted by the Market Committee under this rule". The procedure for applying for licence and the necessary licence fee has also been prescribed thereunder, but they are not relevant for our purpose. The provision of rule 71 makes it obligatory upon every person who carries on any business in any of the agricultural produce in the Market to obtain a licence from the Market committee. The licensee is exposed to various obligations, such as keeping of books in such form and render such periodical returns and at such time and in such form as the Market Committee may from time to time direct and is also to render such assistance in the collection and prevention of the evasion of fees due under the rules and bye–laws. The expression "Agricultural Produce" has been defined in section 2(a) of the Act, which reads as follows:– "Agricultural Produce" includes all produce, whether processed or non-processed of agriculture, horticulture animal husbandry and forest specified in the Schedule (Emphasis is mine). The expression "Agricultural Produce" has been defined in section 2(a) of the Act, which reads as follows:– "Agricultural Produce" includes all produce, whether processed or non-processed of agriculture, horticulture animal husbandry and forest specified in the Schedule (Emphasis is mine). The expression "trade" and "trader" have also been defined in clauses (v) and (w) of section 2, but it is not necessary to refer to those expressions as it is not disputed that the petitioners are traders within their meaning. The pertinent question with which we are concerned in this case is whether the specified commodity "wool" would also include "knitting wool". 3. It is the admitted case that none of the petitioners deal in "wool" as such, but trade only in "knitting wool". The contentions that have been mooted from the side of the petitioners is that when wool under goes a series of processing, it is converted into knitting Wool and is rendered an entirely different commodity. According to the contentions of the contesting respondents, however, although knitting wool may assume a different shape, nonetheless, the expression "wool" which is a generic term would ipso facto include "knitting wool" as well. It is this controversy which has to be resolved in this case. From the definition of "agricultural produce", extracted earlier, it is manifest that within this definition, produce of agriculture, horticulture, animal husbandry and forest have also been included, and the same also includes their "whether processed or non-processed forms". The definition of "agricultural produce" by fiction of law, therefore, has been provided a very wide net to include in its fold various other kinds of products, otherwise which are not under stood to be so included in common parlance within the meaning of "agricultural produce" simplicitor. None the less, in order to be covered under the mischief of the said definition, the produce must be "Specified in the Schedule." The term "Schedule" it self has been defined in clause (r) of section 2 of the Act, as "A Schedule to this Act." Section 39 of the Act, empowers the State Government "By notification to add, amend or cancel any of the items of agricultural produce specified in the schedule." The original schedule, when the Act, was enforced has been amended and expanded from time to time by the State Government. I shall now refer to the schedule itself to answer the question. 4. I shall now refer to the schedule itself to answer the question. 4. The schedule, as it stands at present, has classified the various items mentioned therein under 12 categories, namely (i) Cereals, (ii) Pulses, (iii) Oil seeds, (iv) Oils, (v) Fruits, (vi) Vegetables, (vii) Fibres, (viii) animal husbandry products, (ix) condiments, spices and others. (x) Grass fodder, (xi) Narcotics and (xii) miscellaneous. We are concerned in this case with the eighth category namely, animal husbandry products. There are 14 items in this category and the item relevant for our purpose is the sixth item which is "wool" and the twelve items, which is "fleece". 5. Now I proceed to deal with the two products specified in the Schedules, namely, "fleece" and "wool" and to indicate as to what actually they mean and how "wool" and "knitting wool" are processed and manufactured, in order to appreciate the controversy raised. The petitioners filed a supplementary affidavit to the counter–affidavit filed on behalf of respondents 2 and 3, which I propose to deal with earlier. In this supplementary affidavit, the petitioners have dealt upon the process of manufacturing knitting wool. To this affidavit, they have also annexed a letter dated July 2, 1975, of the Bengal National Textile Mills Ltd. a leading manufacturer of knitting wool, in reply to a query made by one of the petitioner after the controversy arose. It has been stated therein that Marino wool is derived from the clips of fleece, i e. Australian sheep. The fleece is imported in India in its raw form and then it is accursed and combed by commission combers, The process involves cleaning of wool; removing of grease and other foreign matters and thereafter converting wool into continuous silver. This silver is wound on a machine and converted into ban which in trade is called wool top. This wool top again has to go through seven processes before it is converted into woolen yarn. This woolen yarn is further processed in special kinds of machines to bleach dye and convert into finished product called knitting yarn. This imported Marino raw wool is said to be marketed in the country only by licensed importers. This wool top again has to go through seven processes before it is converted into woolen yarn. This woolen yarn is further processed in special kinds of machines to bleach dye and convert into finished product called knitting yarn. This imported Marino raw wool is said to be marketed in the country only by licensed importers. In course of the discussion and as also stated in the supplementary affidavit, the petitioners produced before the court for our inspection fleece which is clipped from the sheeps and its con version into raw wool, after treating the fleece by combing process, as indicated above and the said wool converted into silver. 6. The Case of the petitioners is that even though "agricultural produce" includes all products; whether processed or non–processed every produce intended to be brought in within the purview of "agricultural produce" must be specified therein, unless it is not done, the authorities will have no jurisdiction to enforce the provisions of the Act, in relation to the said article. Their case is that the expression "wool" as such does not cover "knitting wool" which is exclusively used for knitting purpose, such as sweaters, and is as much as the petitioners do not deal in "wool" as such, they were not obliged to take any licence. According to their case, in the absence of incorporation of "knitting wool". In the schedule of the Act, the mischief of the Act, has got no application to them. In order to elucidate their point, the petitioners have also made reference to some other scheduled commodities to show that whenever it was intended to incorporate any species or bye or finished product of any particular commodity, it was specifically brought in under the fold of the schedule. For example, although milk itself has been declared to be an agricultural produce, its processed products Chhena and Cream prepared out of it, have also been separately declared, and again although various oil seeds have been mentioned in the schedule their products have been separately mentioned in a separate category of oil, as already indicated above. The petitioners protested to the respondent Market committee for its insistence to take out licence by them on the above ground, but the Market committee instead has issued notice to them on 8th of May. The petitioners protested to the respondent Market committee for its insistence to take out licence by them on the above ground, but the Market committee instead has issued notice to them on 8th of May. 1976 to the effect that unless they take out licences within three days there from, they would be prosecuted under section 48 read with rule 98 (XII) of the Rules. Copies of those notices are Annexure 3 to 3 (b) to the writ application. 7. Counter affidavit has been filed on behalf of respondents 2 and 3 namely, the Secretary of the market committee and the Market Committee itself. The stand taken by these respondents is that the notified agricultural produce "wool" includes all its forms both processed and un–processed and thus includes "knitting wool" as well and, therefore, the petitioners are liable to obtain a valid licence as provided under the rules and market fee is leviable on the transaction of sale and purchase. The stand taken in the counter-affidavit is that once an agricultural produce was included in the schedule, then ipso facto all species, whether processed or un-processed, would be included in the item, and as "knitting wool" is, in fact, a processed form of "wool" it was included in the expression "wool", as was also understood in common parlance in trade. In order to emphasise this stand, these respondents have also annexed a receipt granted by petitioner no. 1 showing sale of knitting wool where they described the commodity as "sunshine wool". Proceeding further, in paragraph 8, these respondents have rather taken a categorical stand stating that "it is not necessary to specify all the species of the notified agricultural produce in the Schedule. There are various items given in the schedule where only the genus is used and not species, such as wood and tobacco, and wood includes timber, similarly, tobacco includes biri tobacco and chewing tobacco etc.... with respect to some of the illustrations cited by the petitioners in their writ application for incorporating chhena and cream, when milk was notified, these respondents have pleaded that "that has been done in relation to such products only where trade name of the product is different and changed from the principal product in order to avoid confusion." 8. with respect to some of the illustrations cited by the petitioners in their writ application for incorporating chhena and cream, when milk was notified, these respondents have pleaded that "that has been done in relation to such products only where trade name of the product is different and changed from the principal product in order to avoid confusion." 8. As already said earlier, a reply by way of supplementary affidavit has been filed by the petitioners, in which they have stated that wool has to undergo several processes to reach the stage of yarn out of which knitting wool is manufactured, which is an industrial product, having entirely a different and distinctive feature. A plea which has been stated in this supplementary affidavit and which was also pressed at the time of hearing of the writ application is that the Act, being a fiscal statute, its provisions have to be construed strictly in favour of the subject, and so tax can be imposed by inference or analogy or by probe into the intentions of the Legislature and by considering the substance (If the matter. The petitioners have annexed to this supplementary affidavit the various order forms placed with the manufacturers of knitting wool. Such as Rymond Wollen Mills Ltd. Swastik Knitting wools Co. etc. to show that they always mentioned and described the commodity as "knitting yarn" or "knitting wool." 9. It is well established that the fiscal statute has to be strictly construed. The Supreme Court quoted with approval the following observations of Rowlatt, J. in Cape Brandy Syndicate vs. Inland Revenue Commra, (1921) I.K.B. 64, in the Commissioner of Income Tax vs. The Ajax Products Ltd. A.I.R. 1965 S.C. 1358. "In Taxing Act, one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used." After quoting the above observations, the Supreme Court itself in a very clear term said that "the subject is not to be taxed unless the charging provision clearly imposes the obligation. Equally important the rule of construction is that if the words of a statute are precise and unambiguous, they must the accepted as declaring the express intentions of the legislature". Equally important the rule of construction is that if the words of a statute are precise and unambiguous, they must the accepted as declaring the express intentions of the legislature". The above view has bean reiterated by the Supreme Court it its latest decision in case of Diwan Brothers vs. Central Bank of India, A.I.R. 1976 S.C. 1503, where it has been observed that in case of a fiscal statute, the provisions must be strictly interpreted giving every benefit of doubt to the subject. 10. A large number of authorities were cited on behalf of both the parties to bring home their respective contentions in regard to various other statutes where some particular commodity was notified for either levying excise duty or some other tax or for exempting the same from such liability when attempts were made to either exact tax on a connected product of the said commodity or to claim exemption on that as well by the Revenue or the party in their own turns. In my opinion, as reference to those cases will be of much assistance in coming to the final decision, I will proceed to discuss the same one by one. 11. The first case cited by Mr. S.B. Sanyal appearing for the petitioners is the case of Hajee Abdul Shukoor & Co. vs. The State of Madras, (1964) 15 S.T.C. 719 . This was a case under the Central Sales Tax Act. The question that fell for consideration in that case was as to whether raw hides and skins and dressed hides and skins constituted different commodities or merchandise and, therefore, they could be treated as different goods for the purpose of the Act. The petitioners in that case were dealers in skin in the State of Madras and purchased raw skins from places both within and outside the State. They tanned the same and sold them through their agents in Madras. They were assessed to a certain amount of sales tax in accordance with the Madras General Sales Tax Act, 1939 and the rules framed thereunder, on the turnover of hides and skin purchased in the un-tanned conditions outside the state, but tanned within the State. They tanned the same and sold them through their agents in Madras. They were assessed to a certain amount of sales tax in accordance with the Madras General Sales Tax Act, 1939 and the rules framed thereunder, on the turnover of hides and skin purchased in the un-tanned conditions outside the state, but tanned within the State. Later on, another Act, came into force wherein a special provisions in respect of hide and skins were made and it was provided that in the case of dressed hides and skins, which were not subjected to tax under the General Sales Tax Act, as raw hides and skins at certain rate. This provision was challenged by the petitioner of that case and one of the questions raised was that the persons who had purchased raw hides and skin in the state and had paid sales tax on un-tanned skin, when those hides after being tanned were sold, as they constituted one commodity, tax could not be levied on the sale of hides and skins. It was, however, contended for the State that they were different commodities and constituted two separate categories for purpose of taxation. The Supreme Court accepted the contention of the State and held that hides and skins in the un-tanned condition were undoubtedly different as articles of merchandise than hides and skins. The contentions urged on behalf of the petitioners before the Supreme Court that tanning was only a preservative process which made no change in the nature of the article itself was rejected. 12. Learned counsel for the petitioner then cited the case of Mahabir Singh Ram Babu vs. Assistant Sales Tax Officer, (1962) 12 S.T.C. 248. The question that fell for consideration before a learned single Judge of the Allahabad High Court was as to whether 'cinder' was included in the expression 'coal'. In that case, coal was exempted from Sales Tax. The petitioner also claimed exemption from payment of sales tax in respect of the turnover of cinder on the ground that cinder was also coal. It was held that there was basic difference between 'coal' and 'cinder'. Whereas coal was a mineral dug out of the bowels of the earth without anything more being done to it, cinder was the residue which was left after all combustible property of coal had completely escaped into the atmosphere after burning. It was held that there was basic difference between 'coal' and 'cinder'. Whereas coal was a mineral dug out of the bowels of the earth without anything more being done to it, cinder was the residue which was left after all combustible property of coal had completely escaped into the atmosphere after burning. Reliance, however, was placed on the dictionary meanings of 'coal' and 'cinder' where, 'cinder' was sometime described as 'coal'. It was observed in that case that in dictionaries the meaning of one word must be elucidated by reference to other words and the mere fact that words were explained and elucidated by reference to other words, was not the final tests of the exact shape of meaning of a particular words. Reference was made again to a case reported in the same volume in British Indian Corporation Ltd. vs. State of U.P. & others, (1962) 15 S.T.C. 459. That was a case under the U.P. Sales Tax Act, and the question that fell for consideration before the learned Single Judge of the Allahabad High Court was as to whether 'woollen carpet yard' was included in the entry 'woollen goods and knitting wool' because "knitting wool" which is a particular kind of woollen yarn, had been specifically added to the general description of "woollen goods" and therefore, it did not follow that other classes of woollen yarn should be deemed to have been excluded from that description. Learned counsel placed reliance upon this decision to show that the expressions "knitting Yarn" and 'knitting wool' have got different connotations than 'wool'. For the same purpose, he also placed reliance upon some of the provisions of woollen Textiles (Production and Distribution Control) order 1962, a Central order issued under section 3 of the Essential Commodities Act. This order was made "to co-ordinate production of wool tops, woollen yarn or woollen cloth with the needs of the general public." In this order, all the three classes of commodities (woollen cloth, 'woollen Yarn' and 'wool top') have been separately defined under clause 2 of the order. Reference may be made to the two definitions which may be more relevant for our purpose, namely, 'woollen yarn' and 'wool top'. Whereas 'wool top' has been defined to meanal combed woollen silver used for spinning woollen worsted Yarn. Reference may be made to the two definitions which may be more relevant for our purpose, namely, 'woollen yarn' and 'wool top'. Whereas 'wool top' has been defined to meanal combed woollen silver used for spinning woollen worsted Yarn. 'Woollen Yarn' has been defined to mean Yarn manufactured either wholly from wool or partly from wool and partly from any other material and includes worsted and shaddy yarn. 13. Reliance was next placed on behalf of the petitioners on the case of Sevgun Iron & Steel Rolling Mills, Gobindgrah vs. The State of Punjab & other, (1961) 12 S.T.C. 590 , decided by a Bench of the Punjab High Court. This was a case under the Central Sales Tax Act, and the question was as to whether when steel is rolled into rolled steel sections, the outcome is a different and when it is sold, there is a sale of different commodity and a new commodity and not a sale of steel over again. In that case the petitioner had claimed immunity from the liability to pay purchase–tax on the rolled steel materials as the nature and character of the commodity did not under go any alteration. The item mentioned in section 14 of the Central Sales Tax Act, (Clause IV) was 'Iron and Steel' as one of the goods declared of special importance. It was held that the raw material of iron or steel that the petitioner purchased and rolled the same is turned into rolled steel sections this out come was a new commodity. A similar view has been taken by the Supreme Court in the case of Devi Dass Gopal Krishnan & other vs. State of Punjab & other, (1927) 20 S.T.C. 430, which was again a case under the Punjab General Sales Tax Act, 1948, where it was held that where there is a purchase tax on oil seeds or steel scrap and steel ingots or cotton, and sales tax on oil and oil cake or rolled steel sections or yarn after manufacture, it could not be said that the same goods are taxed at two stages, since the manufacture changed the identity of the goods purchased and the goods sold. Proceeding further, it was observed that when oil is produced out of oil seeds, the process certainly transforms raw material into different article for use and oil–seeds cannot be said to be used in different article and the process whereby scrap iron loses identify and becomes rolled steel sections, is one of manufacture. Reference in this connection may also be made to another decision of the Supreme Court in the State of Madras vs. Belhi Mark Tobacco Co., (1967) 19 S.T.C. 129 . The respondents in that case, who were dealers in tobacco products, were assessed to sales tax on the turnover from the sales of "chewing tobacco," Chewing tobacco was prepared out of raw tobacco after various processes and applying jaggery juice and flavouring essences as well as generation of heat. It was then packed in special wrappers which were known as 'chewing tobacco' packets. It was held that the various processes to which the raw tobacco was subjected amounted to manufacturing process and therefore, the chewing tobacco sold by the respondents was not the same commodity as raw tobacco purchased by them. 14. By citation of the above authorities as well as various provisions of the Agricultural Produce Markets Act, and the Wollen Textiles (Production and Distribution Control) order 1962, Mr. Sanyal strongly contended that inspite of the inclusive definition of the term agricultural produce which empowers the State Government to notify various other commodities which were technically not agricultural produce but were products of horticulture, animal husbandry or forest, including their finished and unfinished products in order to attract the Provisions of the Act, it was necessary that the specific produce, either in its original form or in any processed form, must be specifically defined and unless it was so done, any trader dealing in that material was not obliged to submit to the provisions of the Act. 15. 15. In order to meet the contention, learned Solicitor General who appeared on behalf of two of the respondents, took the stand, as already indicated earlier, that by the inclusion of the commodity 'wool' in its most general and widest form, it was intended by the legislature or, for that, the State Government, to embrace within its fold all the different forms to which the commodity 'wool', the basic material, might be reduced or changed by the Act, of processing, and inas–much as knitting wool was nothing else than a processed form of wool, it was not necessary to notify this commodity separately in the Schedule. With respect of the other notified commodities under the same group of animal husbandry product, such as Chhena, cream, butter and ghee, etc. which are products of milki, another notified commodity under this category, the learned Solicitor General contended that if a larger and generic word was used, then it will not be limited by the use of any specific word, that is, when a genus is used without any species, then there was, no limitation and the said genus would include all reasonable species. It was only when a word of limitation was provided then only it will be limited. In other words, he propounded the same thereby which has been set up in the counter affidavit to the contesting respondents. 16. It is difficult to accept this bold contention of the learned Solicitor General. In my opinion, if this could be the intention of the legislature, then there was no necessity of providing in the definition of 'agricultural produce' the power to include all produce, "whether processed or non–processed". It has not been disputed before us that knitting wool is not the primary wool, but is a resultent after the wool in its raw form undergoes several treatments and manufacturing processes, as has already been indicated earlier. I have already said earlier that processed and finished products of agriculture, horticulture, animal husbandry and forest have been sought to be included in the definitions of 'agricultural produce' by giving an artificial and extended meaning to the expression which was, however open to the Legislature. I have already said earlier that processed and finished products of agriculture, horticulture, animal husbandry and forest have been sought to be included in the definitions of 'agricultural produce' by giving an artificial and extended meaning to the expression which was, however open to the Legislature. But I am not prepared to hold that simply because now parent product of either agriculture, horticulture, animal husbandary or forest is specified in the schedule without any of its species which may be produced after any processing than that by itself would be sufficient to incorporate and include within its womb all those bye products or finished products. Such construction in my opinion, of a fisca statute would not be a proper and reasonable construction and would amount to reading in the schedule something by considering as what is the substance of the matter and then substituting other materials by following the rule of intendment and then by implication to read that knitting wool, a commodity which is apparently different, would be covered in the expression 'wool'. 17. The Learned Solicitor General also cited a few decisions in support of his contention. Firstly, he placed reliance upon the case of M/s Tungbhadra Industries Ltd. vs. Commercial Tax Officer, A.I.R. 1961 S.C. 412. This was again a case under the Madras General Sales Tax (Turnover and Assessment) Rules. (1939). The situation in that case was however entirely different. The question involved in that case was as to whether when the raw material groundnut oil was converted in to refined oil after some processing, which is known as hydrogenated oil, or in common parlance, vegetable oil, it still continued to be ground nut oil, a commodity notified under the said Rules The hydrogenated oil was, no doubt, held to be ground nut oil by the Supreme court on the reasoning that when raw groundunt oil is converted into refined oil there is, no doubt, processing; but this consists merely in removing from raw groundnut oil that constituent part of the raw oil which is not really oil, rendering the oil content of the oil 100 percent and there is no use to which the groundnut oil can be put for which hydrogenated oil could not be used. Therefore, hydrogenated oil still continues to be 'ground nut oil' notwithstanding the processing which is merely for the purpose of rendering the oil more stable thus improving its keeping qualities for those who desire to consume "groundnut oil". The reason for treating the processed and unprocessed oil given by Supreme court apparently cannot be of any assistance to the contesting respondents and does not require much elaboration because on the facts of the case on hand, it cannot be contended that knitting wool and wool in its raw form are the same thing. The considerations and the principles which prevailed upon the learned Judges of the Supreme Court to declare hydrogenated groundnut oil and groundnut oil in its raw form to be the same thing cannot be applied to these two commodities. 18. The learned Solicitor–General also placed reliance upon a decision of the Supreme Court reported in the State of Gujrat vs. Sakarwal Brothers, (1967) 19 S.T.C. 24 . The question that had arisen in this case was as to whether patasa, hardas and alchidana fell within the definition of 'sugar' which was entry No. 47 of schedule A to the Bombay Sales Tax Act, 1959. Sugar was exempted from payment of sales-tax and the respondents who were dealers in the above mentioned articles which were prepared out of sugar, also claimed exemption for those items. Although sugar was not separately defined in the sales Tax Act, in question, the Supreme Court referred to its definition as given in the Central Excise and Salt Act, 1944. In that Act, the definition of 'sugar' was as under:– "Sugar means any form of sugar containing more than 90 percent of sucrose." On behalf of the State of Gujrat, it was contended before the Supreme court that the words 'any form of sugar' referred to any variety of sugar and that the words did not mean sugar in any form as according to the State of Gujrat, the word, 'form' was used to indicate varieties of sugar. Repelling this argument, the Supreme court, with reference to various other entries, held that the words 'any form of sugar' were intended to cover sugar in any form, by whatever name it may be called as the qualifying words were that it must contain more than 90 percent sucrose, and, therefore, the entry intended to include within its ambit all forms of sugar, that is to say, sugar of any sort or texture, colour or density and by whatsoever name it is called. In my opinion, this decision is quite distinguishable as although it was observed by the Supreme Court that patasa, harda and alchidana bore a distinct and different name of sugar and were not commercially purchased or sold as sugar, but inasmuch as the Legislature in entry no. 47 did not use the word Sugar simplicitor, but intended to cover sugar in any form which contained more than 90 percent Sucrose, a definition which referred to the chemical contents of an article. The above observations are enough to distinguish the said case as in the case before us the relevant entry in the Schedule, the word used is 'wool' simplicitor. 19. Reliance was next placed by the earned Solicitor General on a Bench decision of this court in the case of the Singhbhum Tobacco & Biri Merchants Association & another vs. Assistant Superintendent of Sales Tax, Chaibasa & another, (1960) 11 S.T.C. 808 . The matter arose out of the Additional Duties of Excise (levy and Distribution) Act, 1957, and Bihar Sales Tax Act, 1947. On 14 December, 1957 a notification was issued by which the word 'tobacco' as defined in the additional Duties of Excise (levy and Distribution) Act, 1957 was to include hand–made Biries i.e. biris manufactured from tobacco by a process of manual labour and exempting those Biris from payment of Sales tax. On the strength of this notification, the petitioners who were carrying on the business and trade in Biris, claimed exemption, the claim was allowed by this court with reference to the definition of 'tobacco' in the Central Excise and Salt Act, 1944, which was to mean 'any form of tobacco whether cured or uncured and whether manufactured or not and includes the leaf, stalks and steams of the tobacco plant but does not include any part of a tobacco plant while still attached to the earth. The court therefore, took into consideration the definition of 'tobacco', which was given in very wide terms in the Excise Act. The position as already indicated earlier is entirely different in the present case, where 'wool' has been described in the Schedule. 20. The learned Solicitor–General then relied upon the dictionary meaning of the word 'wool'. The meaning assigned to this word in Chambers Twentieth Century dictionary is as follows:– A modification of hair in which the fibres are shorter, curled, and possess an imbricated surface the corering of sheep & co. short thick human any light fleecy substance like wool thread or yarn made from animal wool "fabric woven or knitted from it." Learned counsel contended that thread or yarn made from animal wool were already included in the expression 'wool' the product which was notified in the Schedule and therefore, they need not be notified separately. In the case of Mahabir Singh Ram Babu (supra) also, reliance had been placed on the dictionary meanings of 'coal' and 'cinder'. In dictionaries 'cinder' is some time described as 'coal'. It was, however, observed in that case that in dictionaries, the meaning of one word must be elucidated by reference to other words, but authorities competent to speak on the subject were of the view that strictly speaking, there are no synonyms in the English language and, therefore, the mere fact that in dictionaries words are explained and elucidated by reference to other words, could not be the final test of the exact shade of meaning or a particular word. The court takes judicial notice of ordinary meaning of all words spoken and the dictionaries are admitted not as evidence, but only as aids to the memory of understanding of the court, Dictionaries can hardly be taken as authority exponents of the meaning of the words used in the Legislative enactments, for, the plainest words may be controlled by reference to the content. It is established rule of interpretation that general words in statutes should be taken in their usual sense and the rule of ejusdem general is must be applied with great caution because it implies a departure from the natural meaning of the words in order to give them a meaning or a supposed intention of the legislature. 21. Mr. It is established rule of interpretation that general words in statutes should be taken in their usual sense and the rule of ejusdem general is must be applied with great caution because it implies a departure from the natural meaning of the words in order to give them a meaning or a supposed intention of the legislature. 21. Mr. Sanyal invited our attention to the dictionary meaning of 'cotton' given in the aforesaid chamber's dictionary, which includes, the plant itself, individually or collectively yarn or cloth made of 'cotton'. These meanings given to 'cotton' in the dictionary, therefore, also illustrate the view that strictly speaking there are no synonyms in the English language and other words used to elucidate a subject would not determine the final test of the exact shade of meaning of a particular word. I therefore hold that it would not be proper to take any assistance from the dictionary meaning of the word 'wool'. In this connection, the dictionary meaning of the word 'fleece' also may be referred to, which is 'a sheep's coat of 'wool' the wool shorn from a sheep at one time anything like a 'fleece'. We have seen earlier that 'fleece' is also one of the schedule commodity in the Act, and is the primary raw material from which raw wool is derived, after some processing and if the genus theory propounded by the learned Solicitor– General is accepted, then inclusion of 'fleece' only in the schedule was sufficient enough to embrance within its fold all the various species, namely raw wool, wool balls, knitting yarn and knitting wool. As already indicated earlier, at one stage he bad argued that if any species was also mentioned after the mention of the genus, than that would amount that the expense and extent of the genus is curtailed and cut to that extent only. If his contention is accepted, then 'fleece' which is undoubtedly the most primary and initial raw material, namely, wool shorn from a sheep, would have been the most generic expression to embrace within its fold all subsequent processed or non–processed products and there was no necessity of notifying 'wool' separately. If his contention is accepted, then 'fleece' which is undoubtedly the most primary and initial raw material, namely, wool shorn from a sheep, would have been the most generic expression to embrace within its fold all subsequent processed or non–processed products and there was no necessity of notifying 'wool' separately. It cannot be disputed that 'wool' like cotton is a separate commodity, out of which any kind of fibre can be manufactured, like yarns from cotton, for the purpose of manufacture of a variety of finished products, such as carpet, blankets, wearing apparels and knitting materials, it may well be that in common parlance, and if I may say loosely, for the sake of brevity, knitting yarn or knitting wool. In which the petitioners are dealing, may be understood also in trade by the simpler expression of wool but considering the legislative provision, in my opinion, it would not be proper to put such a construction to the said expression, particularly when the legislation is a fiscal statute. In the discussion of the large number of authorities although they were considering the expressions used in different legislations, but all of them were fiscal statutes, no doubt, the fundamental approach of construction was the same. It has been seen that whenever any commodity or property was described in any schedule, then its different forms which was commercially different and capable of different and independent use than the said commodity, was held to be a different commodity from the notified one for the purpose of attracting the relevant provisions of the legislation in question, which I need not repeat or enumerate again. 22. From all the above discussions, I come to the conclusion that knitting wool, in which the petitioners trade, is entirely a different commodity and cannot be covered by the notified commodity 'wool' in the schedule of the Act. As already seen, unless a trader transacts any business in any of the notified commodity, he is not obliged to take out a licence. Respondent Nos. 2 and 3, therefore, were not justified in insisting upon the petitioners to take out licence or for the matter of that, follow any of the provisions of the Act, and the Rules. 23. I would, accordingly, allow this application and quash the notices, contained in Annexure 1, l/a and l/b and Annexure 3, 3/a and 3/b issued by respondent nos. 2 and 3. 23. I would, accordingly, allow this application and quash the notices, contained in Annexure 1, l/a and l/b and Annexure 3, 3/a and 3/b issued by respondent nos. 2 and 3. The respondents must also pay the costs of this application to the petitioners. I would, however, assess the hearing fee at Rs. 250/- only. I agree. Application allowed.