JUDGMENT H.N. Seth, J. - Sixty two petitioners who ply their stage carriages in an area within the control of the Passenger Tax Officer, Muzaffarnagar, have approached this Court for relief under Article 226 of the Constitution. 2. Various petitioners entered into agreements contemplated by S. 5 of the U.P. Motor Gadi (Yatri-Kar) Adhiniyam (hereinafter referred to as the Adhiniyam) read with Rule 5, of the Rules framed under the Adhiniyam, to pay passenger tax in a lump sum. In pursuance of the said agreements which were arrived at after taking into consideration the number of trips which, as authorised by the Regional Transport Authority, petitioner's vehicles were entitled to make as also the fare expected to be received by them, the petitioners became liable to pay the following amounts as passenger tax: 1. Petitioners first set (petitioners Nos. 1 to 43) Rs. 1350/- p.m. 2. Petitioners second set (petitioners Nos. 44 to 61) Rs. 1050/- p.m. 3. Petitioners third set (petitioner No. 62) Rs. 600/ p.m. 3. In November 1979 and the months following, there was great shortage of diesel in the district because of which the petitioners were not able to make the number of trips which they had been authorised to do by the regional transport authority. They approached the district authorities a number of times and requested them to make suitable arrangement for supply of sufficient quantity of diesel to them so that they could ply their vehicles regularly. When it was found that the requisite quantity of diesel could not be made available to them, they, at the instance of the Sub-Divisional Magistrate, Muzaffarnagar, agreed to considerably reduce the number of trips which their vehicles were authorised to make. However, as the Passenger Tax Officer was, despite the fact that the petitioners were not able to make the authorised number of trips because of non-availability of diesel, demanding from them passenger tax in accordance with the agreement entered into by them, they approached the District Magistrate and requested him to intervene in the matter and to persuade the Passenger Tax Officer not to press his demand for payment of passenger tax in accordance with the agreements. As the position regarding diesel supply further deteriorated, the Commissioner and Secretary, Food and Civil Supplies, Uttar Pradesh sent a radiogram dated 7th Jan., 1980 to all Collectors in the State informing them about the priorities which had to be observed by them in issuing diesel for various purposes. According to this radiogram only 25 litres of diesel could be made available to each of the transporters after meeting the requirements of hospitals, election vehicles, corporation etc. Consequently the number of trips which the petitioner's vehicles could make went down still further. Even though the district authorities realised the difficulties of the petitioners and assured them that the needful will be done in regard to their liability for passenger tax under the agreements entered into by them, the Passenger Tax Officer insisted that the petitioners should pay the tax in accordance with their agreements. The petitioners have, therefore, approached this Court for relief under Article 226 of the Constitution. They pray for a direction in the nature of mandamus commanding the Passenger Tax Officer, Muzaffarnagar to charge from them passenger tax only on the basis of actual trips undertaken by them and not on the basis of their agreements. They also claim a writ, order or direction requiring the District Magistrate, Muzaffarnagar to, from out of available quantity of diesel, supply to them same quantity of diesel as was being supplied to the U.P. State Road Transport Corporation. However, in view of changed circumstances, learned counsel for the petitioners has confined his submissions with regard to the first of the aforementioned two reliefs only. 4. Under Section 3 of the Adhiniyam an operator is required to pay to the State Government a tax on every passenger carried by his stage carriage, at a rate equivalent to 15% of the fare payable by such passenger. Section 5 of the Adhiniyam, which lays down the method of collection of tax, also enables the State Government to accept or agree to accept a lump sum in lieu of the amount of tax that may be payable by the operator to the State Government. Section 5 of the Adhiniyam, which lays down the method of collection of tax, also enables the State Government to accept or agree to accept a lump sum in lieu of the amount of tax that may be payable by the operator to the State Government. Rule 5 of the U.P. Motor Gadi (Yatri-Kar) Niyamawali, 1962 (hereinafter referred to as the Niyamawali) lays down that the maximum of the lump sum amount that an operator can be called upon to pay is to be calculated in accordance with the formula F X T X R where F stands for total fare normally payable in respect of the entire route for the full seating capacity and 15% of the standard capacity, if any allowed; T stands for the number of one way trips allowed or expected to be made by such carriage on the route during the period for which the lump sum is calculated, and R means the rate of tax levied under Section 3 to be expressed in the form of fraction such as when the rate of tax is 10% of the fare it would be 10/100. According to sub-rule (7) of R. 5 of the Niyamawali, the agreement to pay passenger tax in a lump sum shall be subject to the condition that any change in the route, trips, seating capacity or fare of such carriage which has likely effect of increasing receipts of the operator therefrom shall render the agreement void with effect from the date of such change and the amount, if any, paid by the operator under the agreement in excess of the proportionate sum payable or the period during which the agreement remained in force shall be refunded or adjusted towards any other amount due from the operator. According to sub-rule (8), if an agreement has become void under sub-rule (7) it will be open to the operator to enter into a fresh lump sum agreement in respect of the unexpired period of the previous agreement. 5. Learned counsel for the petitioners contends that in this case because of nonavailability of diesel in months following November, 1979, there has been a change in the trips that could be made by the petitioner's vehicles. 5. Learned counsel for the petitioners contends that in this case because of nonavailability of diesel in months following November, 1979, there has been a change in the trips that could be made by the petitioner's vehicles. The expression 'which has the likely effect of increasing the receipts of the operator therefrom' used in sub-rule (7), should in the context, be interpreted as meaning 'which has the likely effect of decreasing the receipt of the operator therefrom' as well. Since in the instant case change in the number of trips to be made by the petitioners had resulted in decreasing the receipts of the operator, sub rule (7) becomes applicable and the agreement for payment of a lump sum in lieu of the tax payable under Section 3 of the Adhiniyam has become void. The Passenger Tax Officer is, therefore, not entitled to demand the tax for any period subsequent to Nov. 1979 in accordance with the agreement. 6. In our opinion the submission made by the learned counsel for the petitioners is not tenable. In the first place what the expression "Change in the trips which has the effect of increasing the receipts of the operator" appearing in sub-rule (7) contemplates is a change in the trips authorised by the transport authorities. So long as the transport authorities do not take steps to alter or change the number of trips that an operator is authorised to make in accordance with the terms and conditions of his permit, it cannot be said any change in the trips as contemplated by sub-rule (7), has been brought about. Such change in trips has no bearing on the number of trips actually made by the operator for any reason whatsoever, including that for non-availability of diesel. So long as the transport authorities do not make an order which had the effect of altering the number of trips that an operator is authorised to make under the permit granted to him, it cannot be said that there has been any change in the trips which has a bearing on the validity of the lump sum agreement contemplated by sub-rule (7). 7. Moreover, the change contemplated by sub-rule (7) which renders the agreement void, is a change which has the effect of increasing the receipts of the operator. 7. Moreover, the change contemplated by sub-rule (7) which renders the agreement void, is a change which has the effect of increasing the receipts of the operator. In the instant case the effect of the change relied upon by the petitioners had the effect not of increasing their receipts but that of decreasing their receipts. Learned counsel for the petitioners submitted that on the basis of rule of harmonious construction and for doing justice between the parties, this Court should read the words "increasing the receipts" occurring in sub-rule (7) as including within its ambit a case where the receipts by the operator are decreased as well. The expression "increasing the receipts" has only one meaning, namely, that of the receipts becoming more than what they were earlier. It possibly cannot cover a case where the receipts are less than what they were earlier. Question of applying a rule of construction arises only if the words used in a statute are capable of being interpreted differently. Where the rule-making body clearly intends rendering of an agreement void in a case where the receipts are increased, the courts cannot extend the meaning of the expression and to say, on the ground of harmonious construction or for doing justice, that the rule also meant to cover a case where the effect of change in trips was to, instead of increasing, decrease the trips. We find that notwithstanding the provision contained in sub-rule (7) making an operator liable to pay passenger tax in lump sum whenever the situation required that some relief should be given to operators and the matter was brought to the notice of the State Government, it took remedial measures, made changes in the rules and granted them appropriate relief. For example, in the year 1962 it introduced sub rule (8A) and provided that any change in the rate of tax which comes into force after the date of agreement shall have the effect of marking a corresponding (proportionate) change in the lump sum agreed upon in relation to that part of the period of agreement during which the changed rate remains in force. It follows that notwithstanding that the lump sum agreement subsisted, if as a result of any alteration in the rate of fare the receipts of the operator were to be decreased, the amount payable by the operator under the agreement would also be proportionately decreased. It follows that notwithstanding that the lump sum agreement subsisted, if as a result of any alteration in the rate of fare the receipts of the operator were to be decreased, the amount payable by the operator under the agreement would also be proportionately decreased. Like-wise the rule-making body substituted the existing sub-rule (9) in the year 1969 and laid it down that where an operator, who had deposited the tax in a lump sum, proves to the satisfaction of the Passenger Tax Officer that such carriage was not used for a continuous period specified therein during the subsistence of the lump sum agreement due to reasons specified therein, the Passenger Tax Officer was authorised to refund certain amount of tax to the operator. Unfortunately the present case is not covered by sub-rule (9) as it stands. But then the history indicates that the State Government has, as and when difficulties were brought to its notice, taken steps to amend the rules and to grant relief to the operators. 8. In the instant case there is no doubt that hardship has been caused to the petitioners due to reasons which nobody could foresee. Admittedly the rule-making body did not provide for relief to operators in such contingencies. In absence of an appropriate rule the petitioners are not entitled to obtain any relief from this Court but then they may approach the State Government which may, if it so likes, after taking into consideration the fact that the petitioners were, because of non-availability of diesel for reasons beyond everybody's control, not able to fully ply their stage carriages and that their earnings were considerably reduced, think of providing some relief to the petitioners by way of not taking steps to realise the entire passenger tax due from them. 9. Moreover, it is significant to note that the petitioners in this petition do not claim that the agreement has been rendered void under sub-rule (7) of R. 5 of the Niyamawali. What they actually pray is that the amount due under the agreement be reduced in proportion to the reduction in the actual number of trips made by petitioner's vehicles. Such a prayer does not appear to be justified by anything contained in R. 5 of the Niyamawali. 10. In the result, this petition fails and is dismissed. In the circumstances, we direct the parties to bear their own costs.