JUDGMENT Amarenda Nath Varma, J. - This group of petitions raises a question as to the interpretation of Entry 15 of Schedule 1 to the Water (Prevention and Control of Pollution) Cess Act, 1977 (the Cess Act, in short). Under this schedule various industries have been specified as liable to levy of cess under the said enactment. The question which falls for determination is whether the petitioners industries are covered by Entry 15 of the aforesaid schedule which speaks of processing of animal or vegetable products industry. 2. Most of the questions sought to be raised by Sri Sudhir Chandra, the learned counsel for the petitioners in these petitions, stand concluded, in our opinion by the decision of this court in the case of the Kisan Sahkari Chini Mills Ltd. Budaun v. State of Uttar Pradesh and others reported in AIR 1987 Alld. 298. Sri Sudhir Chandra, however, contended that this decision does not lay down the law correctly. 3. Having given a careful consideration to the submissions of Sri Sudhir Chandra, we are not persuaded that the law laid down as to the interpretation of the relevant provisions of the Cess Act by the Division Bench in the case of Kisan Sahkari Chini Mills Ltd. (supra) requires reconsideration by a larger Bench as we find ourselves in complete agreement with the views expressed by the Division Bench in that case. 4. In Kishan Sahkari Chini Mills Ltd. (supra) the argument raised was that sugar industry was not an industry covered by Entry 15 of the First schedule quoted above and, therefore, the petitioner which was running sugar mills was not liable to the levy and collection of cess under the aforesaid enactment. After a very exhaustive analysis of the relevant provisions of both the Cess Act as well as the parent Act namely, the Water (Prevention and Control of Pollution) Act, 1974 the Bench repelled the argument. In interpreting Schedule I to the Cess tAct and the class of industries specified thereunder, the Bench rightly stressed hat the Cess Act has to be read along with the parent Act, viz. the Water (Prevention and Control of Pollution) Act, 1974 (the 1974 Act, in brief). In interpreting Schedule I to the Cess tAct and the class of industries specified thereunder, the Bench rightly stressed hat the Cess Act has to be read along with the parent Act, viz. the Water (Prevention and Control of Pollution) Act, 1974 (the 1974 Act, in brief). Another postulate on which the Bench proceeded was that in construing the scope of Entry 15 of Schedule L to the Cess Act the purpose of the enactment as well as the mischief designed to be curbed by the law makers must be kept in view. The Bench observed : "Having given our thoughtful consideration to the submissions made by the petitioners' counsel, we are of the view that while finding meaning of a word, it is necessary that the legislative purpose is taken into consideration. If the purpose is ignored, the legislative intent would get lost in be wilderness.......... Another principle which has to be kept in view while interpreting Entry 15 of Schedule I is the context in which that was made......... It has been said by some one that words are partly known by their backgrounds, their past, like men, and like men they do not have their full significance when standing alone, but are known by the company they keep. Full effect of the word is felt only when the context in which it has occurred is not ignored................ we have not only to consider the Cess Act, but also the Pollution Act." 5. We entirely agree with the learned Judges that in construing the provisions of the Cess Act, the purpose and objections of the 1974 Act must be kept in view. The true meaning and scope of the entries of the First schedule of the Cess Act hence cannot be ascertained and appreciated divined from the context of the 1974 Act This has been made explicit by the statement of Objects and Reasons of the Cess Act which unmistakably indicates that the Cess Act was being enacted for providing adequate funds to the State Boards for their effective functioning, i.e., for the efficient discharge of the statutory functions and duties cast on the State Boards under the 1974 Act. 6. 6. The Bench was also right, with respect, in holding that the entries in the First schedule of the Cess Act have to be read along with Section 3 of the Cess Act which provides for the levy and collection of the cess. Under this provision Cess is payable by every specified industry and the basis of calculation of the amount of cess is the water consumed by such an industry for any of the purposes specified in column I of Schedule II. If we turn to that Schedule and examine the purposes enumerated under the first column it would immediately be clear that in the case of industries consuming water the levy is attracted where as a result of processing water gets polluted. 7. Section 3, the charging section, therefore, holds a key to the problem, that is, only those industries are supposed to be specified under Schedule I which are notorious for having the potential of polluting the water consumed by them. We entirely agree with the learned Judge deciding Kisan Chini Sahkari Mills' case that sugar industry is one of the main sources of water pollution. This coupled with the fact that production of sugar undoubtedly involves processing of sugar cane, the industry must be held to be covered by Entry 15 of the First Schedule. 8. What is true of a sugar industry is also true of distilleries engaged in the manufacture of alcohol and alcoholic products as molasses are but a bye-product of sugar produced by the processing of sugar cane. We are fortified have by the decision of this court dated 28-7-1987 in Writ Petition No. 7067 of 1980. 9. Sri Sudhir Chandra next submitted relying on several decisions of the Supreme Court reported in AIR 1972 SC 255 ; AIR 1981 SC 1079 ; AIR 1973 SC 78 and AIR 1977 SC 132 that the cess act being essentially a fiscal Act that meaning should be assigned to the words processing of animal or vegetable products industry which is given to such industries in commercial parlance. In that parlance learned counsel urged, neither sugar industry nor distilleries are known as a processing industry. It was argued that these industries in the world of commerce are essentially known as manufacturing industries in contradiction to processing industries. 10. We are unable to agree. In that parlance learned counsel urged, neither sugar industry nor distilleries are known as a processing industry. It was argued that these industries in the world of commerce are essentially known as manufacturing industries in contradiction to processing industries. 10. We are unable to agree. It ts true that in construing taxing statutes, the rule of interpretation generally accepted is that in assigning meaning to the words used in such statutes the courts should prefer that interpretation which fits with the sense in which those words are understood in the commercial world. But the Cess Act, in our opinion, cannot, for the reasons given above and in greater detail by the learned Judges in the case of Kisan Sahkari Chini Mills Ltd. (supra) be regarded as a fiscal statute pure and simple operating entirely in an independent field and wholly unconnected with and divorced from the 1974 Act. The Cess Act, in our opinion, is an adjunct to the 1974 Act designed expressly to a machinery for raising funds for the administration of the law enacted by the former Act, namely, the 1974 Act. In the above case, the Bench has aptly observed : from a reading of the Pollution Act alone, with the Cess Act, it would be found that the Cess Act is dovetailed into the Pollution Act. 11. It will, therefore, be an error to examine the issue entirely on the basis of commercial parlance. The contextual backdrop in which the First Schedule is set cannot be lost sight of in construing the entries. 12. Further, the language used in Entry 15 is not processing industry but processing of animal or vegetable products industry which are words of much wider amplitude. If the production of sugar involves, as in our opinion it does, processing of vegetable products, in the series of stages of production of sugar, the industry would clearly fall within Entry 15. A glance at the industries included in Schedule i would clearly snow that the basis of selecting the industries is not whether an industry is a manufacturing industry or a processing industry. On the contrary, the classification appears to be founded on the consideration whether the industry is one in which there is a possibility of water getting polluted. 13. A glance at the industries included in Schedule i would clearly snow that the basis of selecting the industries is not whether an industry is a manufacturing industry or a processing industry. On the contrary, the classification appears to be founded on the consideration whether the industry is one in which there is a possibility of water getting polluted. 13. We may quote here a passage from the decision in Kisan Sahkari Chini Mills' case (supra) which aptly sums the law thus : "Sugar industry is one of the main sources of causing water pollution. Under the pollution Act, its activities can be controlled and guided. Consequently, the parliament thought of providing a provision in the Cess Act which levies cess on the water consumed by an industry engaged for the purposes specified in column (1) of Schedule II. The Parliament could not have specifically dealt with each industry separately and it was for this reason that the industries falling one category were lumped up together for the purposes of covering them under Schedule I. If we were to examine the schedule, we will find it to be so established by finding that each particular industry is not named therein. The industries in Schedule I have been broadly mentioned. These entries would apply to the industries falling in one or the other entry of Schedule I irrespective of the fact that by name it is not so described." 14. The line of reasoning applicable to sugar industries and distilleries applies with equal validity to the industries engaged in processing milk into milk products at its dairy. As already observed, Entry 15 has to be construed broadly keeping in view the context in which it appears as well as the purpose of the two enactments. So construed, an industry which is engaged in the business of processing milk products would undoubtedly fall within the ambit of Entry 15, milk being animal product. 15. As already observed, Entry 15 has to be construed broadly keeping in view the context in which it appears as well as the purpose of the two enactments. So construed, an industry which is engaged in the business of processing milk products would undoubtedly fall within the ambit of Entry 15, milk being animal product. 15. Lastly, learned counsel contended that Entry 15 is hit by Article 14 of the Constitution of India in that several industries known for their proneness to pollute water have been left out of the purview of Schedule I. Glass, for example, learned counsel contended, is not included among the industries specified in Schedule I even though its potential to pollute water is by no means less than that of other industries which have been roped in under Schedule I. The argument is misconceived. The categorical stand taken by the respondents that glass industry has not been exempted from the operation of the Cess Act and that the same falls within Entry 8 as a ceramic industry furnishes a complete answer to the petitioners contention. Here again Sri Sudhir Chandra contended that glass industry is not known in commercial parlance as ceramic industry and, therefore, it should be taken to have been left out of the purview of Schedule I. 16. We are unable to agree. The entries in Schedule I have to be construed broadly and not in a narrow, restricted sense. They are more a description of the class of industries rather than of individual industries. The Entries mention the genus and not the species. So construed, it is impossible to hold that glass industry is not covered under Entry 8. 17. In the result, the petitions fail and are dismissed with costs.