K. S. PUTTASWAMY, J. ( 1 ) ALL these cases in which common questions of law arise for determination and can, therefore, be disposed of by a common order, had been posted before me to-day for orders on the interim prayer made by the petitioners before issue of rule nisi. But, as agreed to by both sides, these cases are treated as listed for final hearing to-day and are accordingly heard and disposed of by a common order. ( 2 ) ISSUE rule nisi. ( 3 ) THE petitioners who are exhibitors of cinematograph films in their respective permanent theatres situated at different parts of the State are liable to pay taxes under the Karnataka Entertainments Tax Act, 1958 (Karnataka Act 30 of 1958) and the rules framed thereunder (hereinafter referred to as the Act and the Rules ). ( 4 ) BEFORE the petitioners admit their patrons to their theatres to several classes, they issue them printed tickets showing the charges of admission and the taxes payable by them thereto on each ticket which are certified by the concerned Entertainment Tax Officer of the area. The ticket books are generally printed in bulk. Before 1-7-1982 the petitioners had got printed considerable number of ticket books to different classes, got them duly certified making the necessary deposits at the rates of taxes that were then in force. ( 5 ) UNDER an Act called the Karnataka Taxation and Certain Other Laws (Amendment) Act, 1982 (hereinafter referred to as the Amendment Act), that came into force from 1-7-1982, various amendments in the rates of taxes payable under the Act were made to the rates of taxes payable from that date. In other words, the rates of taxes were revised from 1_7_1982. As a sequel to the said amendment, the Commissioner of Commercial taxes (hereinafter referred to as the commissioner) through his subordinates has called upon the petitioners and other exhibitors in the State not to use the earlier unused printed ticket books available with them, but get fresh ticket books printed incorporating the rates of taxes payable under the Act as amended by the Amendment Act. ( 6 ) ON a representation made by the petitioners and others, the Commissioner extended time for compliance of his directions for the month of July 1982 and has again extended the same till 31-8-1982. In these petitions under art. ( 6 ) ON a representation made by the petitioners and others, the Commissioner extended time for compliance of his directions for the month of July 1982 and has again extended the same till 31-8-1982. In these petitions under art. 226 of the Constitution, the petitioners have challenged the aforesaid directions issued by the Commissioner and his subordinates and have sought for a mandamus to them to permit the use of the unused tickets available with them affixing necessary rates of taxes with rubber stamps. ( 7 ) FIRSTLY, the petitioners have urged that on a true construction of the act and the Rules, the use of rubber stamps showing the revised rates of taxes on the unused tickets is permissible. Secondly, the petitioners have urged that the direction of the authorities is unauthorised in law. Alternatively, the petitioners have urged that if the directions are authorised by the Act and the Rules, then, the same places unreasonable restrictions on the freedom of trade and business guaranteed to them under Art. 19 (1) (g) of the Constitution ( 8 ) EVEN this very innocuous relief sought by the petitioners, is vehemently opposed by the respondents. Firstly, the respondents have urged that the petitioners are under an unavoidable legal compulsion to print new ticket books showing the revised rates. Secondly, the respondents have urged that the said legal compulsion is a reasonable restriction on the freedom of trade and business guaranteed under 19 (1) (g), (6) of the Constitution. ( 9 ) SRIYUTHS Viswanath S. Shettar and B. G, Sridharan learned counsels for the petilloners, contend that the directions issued by the Commissioner to the theatre owners to use only new printed tickets showing revised rates of taxes without using the unused declared tickets showing the revised rates are wholly unauthorised, illegal and impermissible. ( 10 ) SMT. M. R. Vanaja, learned high Court Government Pleader, appearing for the respondents urged that the direction to use fresh printed ticket forms, to avoid evasion of taxes and safeguard public revenues, was legal and valid. ( 11 ) BEFORE 1-7-1982, the petitioners having regard to the rates of taxes that were then prevailing had got printed considerable quantity of ticket books of different classes showing the rates of taxes payable by their patrons and had declared those stocks before the authorities. ( 11 ) BEFORE 1-7-1982, the petitioners having regard to the rates of taxes that were then prevailing had got printed considerable quantity of ticket books of different classes showing the rates of taxes payable by their patrons and had declared those stocks before the authorities. It is common knowledge that exhibitors generally place bulk orders for printing ticket books and get them printed well in advance with due regard to the rates of taxes that were then prevailing. ( 12 ) THE Act and the Rules do not prohibit the exhibitors from placing bulk orders for printing ticket books and get them printed well in advance. Before getting the ticket books printed, the petitioners did not expect that the legislature would revise the rates of taxes from a subsequent date. ( 13 ) THE Act and the Rules do not compel the petitioners that have got ticket books printed earlier in bulk, to destroy them and not to use them on the revision of taxes by showing appropriate changes consequent on the revision of taxes in an intelligible method like stamping them with rubber stamps. Secondly, the Act and the Rules do not require that only printed ticket forms should be used and stamping should not be done when there is a revision of taxes, destroying all the unused tickets, without making any changes thereto that becomes necessary by a subsequent legislation. From this it follows that the directions issued by the Commisioner do not flow from the Act and the Rules. ( 14 ) AFTER all, paper, more so printing paper, is in short supply in our country. Unless the Act and the Rules legally compel the destruction of unused ticket books in the new and unexpected situation that developed on which the petitioners had no control, there is no point in the Commissioner virtually compelling the exhibitors to destroy the declared and unused stocks and use only new printed ticket forms. By showing the revised rates with rubber stamps, the object of legislation is not defeated and does not result in any loss of revenue to the State or the petitioners. ( 15 ) RULE 24 of the Rules provides for stamping or such other method to be approved by the authority under the Act. By showing the revised rates with rubber stamps, the object of legislation is not defeated and does not result in any loss of revenue to the State or the petitioners. ( 15 ) RULE 24 of the Rules provides for stamping or such other method to be approved by the authority under the Act. The object of providing for stamping in rule 24 is not without a purpose, In my view, Rule 24 itself, on a proper construction, permits the authority to permit the exhibitors to use their unused declared stocks till they last by stamping them with rubber stamps, ( 16 ) BEFORE the exhibitors issue the unused tickets of declared stocks showing the revised rates with rubber stamps, they have to produce them before the concerned officers, make the requisite deposits and then get them sealed by that officer, after which only they are required to issue those tickets to the patrons. When that is so, how there will be evasion or loss of revenue, solely on the ground that printed tickets are not used, is somewhat difficult to appreciate. The act and the Rules make exhaustive provisions to prevent evasion and loss of revenue to the Stale which can be effectively enforced by the authorities instead of blindly asking the exhibitors to use only new ticket forms. ( 17 ) ON the above discussion, it follows that the directions issued by the commissioner are unauthorised and illegal. In this view, it is unnecessary to examine the challenge of the petitioners based on Art. 19 (l)' (g) of the Contitution, and the same is, therefore, left open. ( 18 ) IN the light of my above discussion, i make the following orders and directions : (1) I quash circulars bearing no. ENT. CR. 276/81-82 dated 30th march, 1982 and 28-7-1982 issued by the Commissioner for Commercial Taxes in Karnataka, Bangalore; (2) I issue a writ in the nature of mandamus to the respondents to permit the petitioners to use their declared but unused ticket books and forms that are available with them as on 30-6-1982 by duly affixing rubber stamps legibly showing payments for admission, new rates of entertainment Tax, Surcharge effective from 1-7-1982 and the totals thereof till the stocks available with them on 30-6-1982 only are exhausted. ( 19 ) RULE issued is made absolute in all these cases. ( 19 ) RULE issued is made absolute in all these cases. But, in the circumstances of the cases, I direct the parties to bear their own costs. ( 20 ) LET a copy of this order be communicated to the respondents within a week from this day. Let another copy be furnished to the learned High Court government Pleader within the same time. ( 21 ) SMT. M. R. Vanaja, learned high Court Government Pleader, is permitted to file her memo of appearance for the respondents in all these cases within 15 days from this day. --- *** --- .