JUDGMENT GopalanNambiyar, C.J. 1. The Judgment of the Court was delivered by Gopalan Nambiyar, C. J. - The appeal is by the Manager of the St. Albert's College, Ernakulam, against the decision of a learned Judge of this Court denying exemption from property tax under S.103 of the Kerala Municipal Corporations Act, 1961 to the Students' Hostels attached to the institution. S.103 of the Act in so far as it is material, reads: "103. Exemptions: (1) The following buildings and lands shall be exempt from the property tax: (a) places set apart for public worship and either actually so used or used for no other purpose; (b) buildings which are attached to places of public worship other than those used for residential purposes; (c) choultries for the occupation of which no rent is charged and choultries the rent charged for the occupation of which is used exclusively for charitable purposes; (d) lands and buildings or portions of lands and buildings exclusively occupied and used for public worship or by a society or body for a charitable purpose: Provided that such society or body is supported wholly or in part by voluntary contributions and applies its profits, if any, or other income in promoting its objects and does not pay any dividend or bonus to its members. Explanation. -"Charitable purpose" includes relief of the poor education and medical relief but does not includes a purpose which relates exclusively to religious teaching; (e) .. .. .. .. (f) .. .. .. .. (g) .. .. .. .. (h) .. .. .. .. (i) .. .. .. .. Explanation.- The exemption granted under this section shall not extend to residential quarters attached to schools and colleges or to residential quarters attached to hospitals, dispensaries and libraries." 2. The question whether residential hostels are liable to be exempted under the main provision, sub-s.(1)(d) of the Act, or the said exemption is liable to be withdrawn by reason of the provision of the explanation appended to the section, fell to be considered by a Division Bench of myself and Eradi, J. in O. P. Nos. 682 and 725 of 1967 and O. P. 77 of 1968. By our judgment dated 12th December, 1969 we held that hostels are not entitled to the exemption. The decision is not reported; but it has been referred to in the judgment under appeal. 682 and 725 of 1967 and O. P. 77 of 1968. By our judgment dated 12th December, 1969 we held that hostels are not entitled to the exemption. The decision is not reported; but it has been referred to in the judgment under appeal. This writ appeal was admitted on 4th September 1975; we find nothing to show that the Bench which admitted the appeal doubted the correctness of the earlier Division Bench Ruling or wanted the matter to be reconsidered. We were a little distressed that in respect of a matter where the law has been settled by a Division Bench of this Court, another Division Bench should have received a writ petition raising the very matter settled. 3. At the hearing of the appeal, Counsel pleaded that the earlier Division Bench ruling requires reconsideration. We have heard the Counsel fully. But, we do not think that any grounds have been made out for reconsidering the earlier Division Bench or for referring the matter to a Full Bench. The earlier Division Bench noted that having regard to the second explanation to the section which we have extracted earlier, it was unnecessary to consider the broad and general question as to whether educational purpose is a charitable purpose within the meaning of clause (d) of the section; and that it would be enough to confine to the limited question whether the expression 'residential quarters' in the second Explanation would include residential hostels also. The Division Bench then observed: ".... Though the expression 'quarters' may have its etymological derivation from the lodgings of soldiers, in its ordinary, dictionary meaning the term means 2 place of stay or residence. (See for instance, the Shorter Oxford Dictionary). So too a hostel in its dictionary sense means a residence or house for students (See the Concise Oxford Dictionary and the Shorter Oxford Dictionary; and Ramanatha Iyer's Law Lexicon). We are unable to agree with Counsel for the petitioner that the term 'quarters' must be restricted in its application to residence provided for the staff attached to the institution and not to that of students. Neither the permanence of occupation of the incumbent nor the magnitude of the accommodation available seem to be decisive of the question whether the habitation can be regarded as 'quarters'. Neither the permanence of occupation of the incumbent nor the magnitude of the accommodation available seem to be decisive of the question whether the habitation can be regarded as 'quarters'. The expression is appropriate as much to the accommodation provided for high paid officers, as for low paid servants and mazdoors. We do not see why it should not apply to students' Hostels. We are therefore of the opinion that students' hostels are 'residential quarters' within the meaning of the second of the explanations to S.103 extracted earlier. The playground being merely appurtenant to the hostel should go along with it. 3. We may point out that exemption was specifically conferred from property tax in respect of hostels by an amendment introduced to S.101, of the Kerala Municipalities Act, 1960, by Act 29 of 1963. " 4. We feel that some additional indication is available from the section itself to define the contours of the phrase 'residential quarters'. Clause (d) of S.103 is the clause with which we are intimately concerned; it refers to residential quarters attached to the schools, colleges and also to hospitals, dispensaries and libraries. No satisfactory explanation has been afforded, and we can find none, why, for instance, residential quarters attached to hospitals would not include, what are generally referred to, as 'nurses' quarters', or 'Nurses' Hostels'. We feel the same consideration applies to residential quarters attached to dispensaries and libraries also. At the end of the elaborate arguments advanced by the appellant's counsel, we feel fortified in the conclusion that, even accepting with counsel for the appellants the popular sense of the term 'residential quarters', we would not be justified in excluding from its scope and content residential hostels attached to the educational institutions, and confining it only to the staff quarters attached to educational institutions for housing Principals, Professors, Lecturers and other members of the staff. There seems to be no warrant for understanding the term in this limited sense. 5. We might in this connection usefully refer to the following exposition of understanding the words in a statute in their popular or commonly understood sense of the term. In The Peermade Tea Company Ltd., Cheenthalar Group, Fair Field in Peermade Taluk v. Executive Authority Upputhara Panchayat and two others ( 1957 KLJ 649 ), the question arose as to the meaning of the word 'house' under the Travancore - Cochin Panchayats Act, 1950. In The Peermade Tea Company Ltd., Cheenthalar Group, Fair Field in Peermade Taluk v. Executive Authority Upputhara Panchayat and two others ( 1957 KLJ 649 ), the question arose as to the meaning of the word 'house' under the Travancore - Cochin Panchayats Act, 1950. The Division Bench of this Court observed: "7. The word 'house' ordinarily means a building for human habitation and it is in that sense that Coke used it when he said: 'The house of every one is to him as his castle and fortress, as well for his defence against injury and violence as for his repose'. (Semayne's case 5 Rep. 91). 'It is one of the surest indexes of a mature and developed jurisprudence not to make a fortress out of the dictionary' [Learned Hand, J. 148 F. (2d) 737] and over the years the meaning of the word has grown and altered. 8. In (1878) 9 Ch. D. 425 Cotton, L. J. said: "With regard to the word 'house'. It is impossible to say it is to be confined to a building used wholly, or almost wholly, for residential purposes". and in (1900) A. C. 383 Lord Halsbury pointed out that 'the word is no longer the expression of a simple idea' but 'an ambiguous word with' no common or ordinary meaning so fixed and definite that by the mere use of the word you can determine in what sense the Legislature has used it. According to him 'one must understand the subject matter with respect to which it is used in order to arrive at the sense in which it is employed in a statute" and must search "otherwise than in the word itself what is the meaning in which the Legislature has used it, since the natural and ordinary meaning of an ambiguous word cannot be ascertained without the context". 9. In (1917) 86 LJ. K. B. 1331 Lord Reading said: "It is certainly not permissible to say that the word 'house' means only a dwelling house. The word has a wider meaning than a dwelling house for human beings". and held that aeroplane hangars were "houses" within the meaning of the Provisional Order before him. He dealt with the decision of the House of Lords in (1900) A. C. 383 as follows: "As was shown by the observations of Lord Halsbury in (1900) A. C. 383, the word is ambiguous. and held that aeroplane hangars were "houses" within the meaning of the Provisional Order before him. He dealt with the decision of the House of Lords in (1900) A. C. 383 as follows: "As was shown by the observations of Lord Halsbury in (1900) A. C. 383, the word is ambiguous. The House of Lords was dealing with the inhabited house duties, and the question was what meaning should be given to the word 'house'. They laid down the rule that in order to understand the meaning of the word it was necessary to consider the object of the statute in which the word is used. In speaking of the judgment of the Master of the Rolls, Sir George Jessel, in 45 L. J. Ex. 886 Lord Halsbury said: 'It establishes undoubtedly that the word 'house' is an ambiguous word; it shows that you must search otherwise than in the word itself what is the meaning in which the Legislature has used it, since the natural and ordinary meaning of an ambiguous word cannot be ascertained without the context. Every word of this reasoning applicable to a case under another statute, is applicable to the case now before us. They expressed a general proposition, and were not confined to the particular statute before the House". The above exposition is instructive; and applying the principle expounded by the Division Bench, we only get confirmed in the view expressed by the Division Bench on the earlier occasion in the case noticed. We follow the said decision of the Division Bench. 6. Counsel for the appellant raised the further contention that there was a violation of Art.14 of the Constitution as the withdrawal of the exemption in respect of residential hostels is only in the Municipal Corporations Act, 1961, whereas, under the provisions of the Kerala Municipalities Act and the Kerala Panchayats Act, students' hostels continue to enjoy the exemption from property tax. Our attention was called to S.101, (cc) of the Municipalities Act, and S.72(d) and the Explanation thereto, in the Panchayats Act. For the one thing we find no trace of this contention having been dealt with in the judgment of the learned Judge; and we should think that the averments in regard to Art.14 of the Constitution are scanty. Our attention was called to S.101, (cc) of the Municipalities Act, and S.72(d) and the Explanation thereto, in the Panchayats Act. For the one thing we find no trace of this contention having been dealt with in the judgment of the learned Judge; and we should think that the averments in regard to Art.14 of the Constitution are scanty. The Statutes are separate and different; and we are not satisfied that buildings within the limits of a Corporation governed by the Municipal Corporations Act stand on the same footing or in the same class as those within the limits of Municipalities under the provisions of the Municipalities Act and the Panchayats Act. On these grounds, we are unable to agree with Counsel for the appellant that the principle of the decision in The State of Madhya Pradesh v. G. C. Mandawar ( AIR 1954 SC 493 ) is attracted. He cited to us the passage at page 496: "On these provisions, the position is that when a law is impugned under Art.13, what the Court has to decide is whether 'that' law contravenes any of the provisions of Part III. If it decides that it does, it has to declare it void: if it decides that it does not, it has to uphold it. The power of the Court to declare a law void under Art.13 has to be exercised with reference to the specific legislation which is impugned. It is conceivable that when the same legislature enacts two different laws but in substance they form one legislation, it might be open to the Court to disregard the form and treat them as one law and strike it down, if in their conjunction they result in discrimination. But such a course is not open where, as here, the two laws sought to be read in conjunction are by different Governments and by different legislatures. Art.14 does not authorise the striking down of a law of one State on the ground that in contrast with a law of another State on the same subject its provisions are discriminatory. Nor does it contemplate a law of the centre or of the State dealing with similar subjects being held to be unconstitutional by a process of comparative study of the provisions of the two enactments. Nor does it contemplate a law of the centre or of the State dealing with similar subjects being held to be unconstitutional by a process of comparative study of the provisions of the two enactments. The sources of authority for the two statutes being different, Art.14 can have no application." We do not think, for the reasons which we have noticed already, that the above principle is attracted. We are unable to hold that there is any violation of Art.14 of the Constitution. We dismiss this appeal, but in the circumstances without costs.