R. N. AGGARWAL, J. ( 1 ) BY this petition under Art. 226 of the Constitution the petitioner M/s. Doon Apartment, a private limited company having its registered office at New Delhi, have challenged the legality and vires of the order Dt. 17th Jan. 1980 by respondent 3 the Joint Chief Controller of Imports and Exports, Bangalore, declining the request of the petitioner for revalidation of the permit for export of two metric tonnes of sandalwood to M/s. Tien Yuan Chemical (P) Ltd. , Singapore. The petitioner has further sought a writ of mandamus directing respondents 4 to 6 to release the sandalwood of the petitioner for export to Singapore. The petitioner has also sought quashing of the criminal proceedings initiated by respondents 4 to 6 against the petitioners. ( 2 ) THE relevant facts are these. The export policy for 1978-79 allowed export of sandalwood. The petitioner entered into a contract with M/s. Day Spring and Co. Ltd. , Taiwan for export of 1 metric tonne of sandalwood. A letter of credit was opened on 17th Sept. 1978. On 10th Nov. 1978 the Union of India issued a public notice banning export of sandalwood. The petitioner approached the Chief Controller of Exports at Madras for permission to export sandalwood on the basis of prior commitment. ( 3 ) ON 6th Dec. 1978 the petitioner purchased one tonne of sandalwood in public auction at Salem Depot, Tamil Nadu and under permit No. 3020 the petitioner removed the said sandalwood by lorry up to Salem railway station and thereafter by rail to Madras for export to M/s. Day Spring and Co. , Taiwan. This one tonne of sandalwood was placed in the custody of M/s. Jayna and Co. , the shipping agents of the petitioner for export from Madras port. On 12th Dec. 1978 the petitioner purchased five tonnes of sandalwood in a public auction and under a permit Dt. 30th Mar. 1979 removed the said sandalwood by lorry to Salem railway station and thereafter by rail to New Delhi. Earlier to this the petitioner had purchased 8-9 tonnes of sandalwood from Salem Depot which were also brought to New Delhi. On 1st Nov. 1979 the petitioner entered into a contract with M/s. Tien Yuan Chemical (P) Ltd. , Singapore for the export of two tonnes of sandalwood to the said company. ( 4 ) ON 9th Mar. Earlier to this the petitioner had purchased 8-9 tonnes of sandalwood from Salem Depot which were also brought to New Delhi. On 1st Nov. 1979 the petitioner entered into a contract with M/s. Tien Yuan Chemical (P) Ltd. , Singapore for the export of two tonnes of sandalwood to the said company. ( 4 ) ON 9th Mar. 1979 the Joint Chief Controller of Imports and Exports, Bangalore, informed the petitioner that the request for grant of export permit was time barred. The petitioner filed an appeal to the Chief Controller of Imports and Exports from the decision of the licensing authority. On 8th Nov. 1979 the petitioner was granted permit for export of two tonnes of sandalwood worth Rs. 1,56,850. 00 to Singapore. On or about 17th Nov. 1979 the petitioner transmitted from Delhi one tonne of sandalwood to its shipping agents at Madras-for export to Singapore. The said sandalwood was seized at Madras railway station by the forest authorities of Tamil Nadu on the ground of absence of permit under the Madras Sandalwood Transit Rules, 1967. The sandalwood already lying with the shipping agent was also seized on the ground that a permit under the Tamil Nadu Sandalwood Possession Rules, 1970 was not obtained. ( 5 ) ON 23rd Dec. 1979 the petitioner wrote to the Joint Chief Controller of Imports and Exports mentioning the circumstances for not exporting the sandalwood within the prescribed period and requested for extension of the period. As already stated, the said request was rejected on 17th Jan. 1980. ( 6 ) MR. C. L. Chaudhary, learned counsel for respondents 1 to 3, does not oppose the petition regarding the prayer for a direction to respondents 1 to 3 to revalidate the licence for the export of the sandalwood. ( 7 ) THE crucial questions that remain for decision are one : whether it is necessary for the petitioner to obtain transit permit under the Sandalwood Transit Rules, 1967 regarding the one tonne of sandalwood despatched by it from Delhi to its shipping agents at Madras, and two : whether it is necessary for the petitioner to obtain the licence for possession of sandalwood already in possession of the shipping agents at Madras for export. ( 8 ) THE contention of Mr. Bhatia, learned counsel for the petitioner, is that the aforementioned rules are not applicable to the sandalwood in question. ( 8 ) THE contention of Mr. Bhatia, learned counsel for the petitioner, is that the aforementioned rules are not applicable to the sandalwood in question. The sandalwood sent by the petitioner from Delhi to the shipping agents at Madras for export has been seized by the respondents 4 to 6 on the ground that a transit licence is necessary. The sandalwood lying with the shipping agents was seized on the ground that the licence for possession under the Sandalwood Possession Rules is necessary and has not been obtained. ( 9 ) RULE 2 of the Tamil Nadu Timber Transit Rules 1968 reads as under : "2. Conditions of transit of timber, No person shall (a) import timber into or export limber from the area specified in Schedule B (not being a town specified in Schedule C) except by the routes specified in Schedule A and unless such timber is accompanied by the permit prescribed by R. 3; or (b) move timber from, into or within the areas specified in Schedule B (not being a town specified in Schedule C) unless such timber is accompanied by the permit prescribed by R. 3; or (c) import or move timber into any of the towns specified in Schedule C unless such timber is reported for examination at the appropriate checking stations specified in that schedule or, as the case may be, at one of the checking stations (specified in the schedule) in or adjoining the town in question : Provided that the Government may authorise any person or persons to import timber into or export timber from, the area specified in Schedule B (not being a town specified in Schedule C) by any route or routes not specified in Schedule A, subject to such conditions as they may consider necessary. Explanation. Timber found on, or on the margin of, any public road, whether loaded in carts or other vehicles or not and timber found in any river or stream whether tied into rafts or not or loaded in boats or coracles or not, and timber found in, or on the margin of, any canal or reservoir, whether tied into rafts or not, or loaded in boats or coracles or not, shall for the purpose of these rules be deemed to be timber in transit. " ( 10 ) MR. " ( 10 ) MR. Bhatia contended that the taking of the sandalwood from Delhi by rail to Madras for the purpose of export does not amount to Importing timber into or exporting timber out of Madras and, therefore, R. 2 will not be attracted. The counsel in support of his contention relied on Central India Spg. and Wvg. and Mfg. Co. Ltd. , and Empress Mills Nagpur v. Municipal Committee, Wardha AIR 1958 SC 341 . ( 11 ) THE cited case is a decision, under the Municipal Act and the question that arose for decision was whether the goods passing in transit through the municipal limits, without loading or unloading or stopping within the municipal limits was liable to the terminal tax. Their Lordships while interpreting the words "imported into or exported from" used in S. 66 (l) (a) of the Municipal Act held as under: ". . . . . . . . . THAT by giving to the words "imported into or exported from", their derivative meaning without any reference to the ordinary connotation of these words as used in the commercial sense, the decided cases in India have ascribed too general a meaning to these words which from the setting, context and history of the clause was not intended. To construe the words "import" and "export" as meaning "bring in" or "take out of or away from" and cover the goods in transit by the words "imported into" or "exported from", would make rail borne goods passing through a railway station within the limits of a Municipality liable to the imposition of the tax on their arrival at the railway station or departure therefrom or both which would not only lead to inconvenience but confusion, and would also result in inordinate delays and unbearable burden on trade both inter-State and intra State. It is hardly likely that that was the intention of the legislature. Such an interpretation would lead to absurdity which has, according to the rules of interpretation, to be avoided. "import" is not merely the bringing into but comprises something more i. e. "incorporating and mixing up of the goods imported with the mass of the property" in the local area. Such an interpretation would lead to absurdity which has, according to the rules of interpretation, to be avoided. "import" is not merely the bringing into but comprises something more i. e. "incorporating and mixing up of the goods imported with the mass of the property" in the local area. Similarly, the word "export" has reference to taking out, of goods which had become part and parcel of the mass of the property of the local area and will not apply to goods in transit i. e. brought into the area for the purpose of being transported out of it. If the intention was to tax such goods then the word used should have been "re-exported" which means to export (imported goods) again. Re- exportation means the exportation of imported goods. Even assuming that the words "imported into" or "exported from" could be restricted only to their derivative meaning and thus construed to mean only "brought into or taken out or away from" this general meaning is qualified by the use of the prefix "terminal" used adjectively with the word "tax". "terminus" means the point to which motion or action ends, goal, end, finishing point; sometimes that from which it starts; starting point; and end; extremity; the point at which something comes to an end. If "terminal" besides the above meaning has an additional meaning also and that meaning signifies the termini or the jurisdictional limits of the municipal area even then the construction to be placed on the term should be the one that favours the tax-payer, in accordance with the principle of construction of taxing statutes, which must be strictly construed and in case of doubt must be construed against the taxing authorities and doubt resolved in favour of the tax-payer. Keeping in view the terms and language and the legislative history of S. 66 (1) the terms of the section cannot be enlarged by mere construction so as to include within its operation goods which are in transit and are being transported across the jurisdictional limits of the Municipality. Therefore the terminal tax leviable under Cl. (o) of S. 66 (1) properly-construed must have preference to some activity within the municipal area i. e. the entry for the purpose of remaining within that area or commencement of journey from that area. Therefore the terminal tax leviable under Cl. (o) of S. 66 (1) properly-construed must have preference to some activity within the municipal area i. e. the entry for the purpose of remaining within that area or commencement of journey from that area. Therefore the terminal tax under S. 66 (1) (o) is not leviable on goods which are in transit and are only carried across the limits of the Municipality and are neither loaded nor unloaded within the municipal area. " ( 12 ) A reading of Tamil Nadu Timber Transit Rules 1968 and the Tamil Nadu Sandalwood Possession Rules 1970 show that the object and the purpose in framing the said rules was to prevent the illicit felling of the timber and to regulate its movements within the various revenue districts and the various forest divisions specified in the annexure to the said rules. The expression or the words "import timber into or export timber from the areas specified in Schedule B" used in R. 2a has to be interpreted keeping in mind the object and the purpose of the rules. The expression "imported into or exported from" employed in R. 2a in my opinion, has to be given its ordinary dictionary meaning. Once the sandalwood is brought into Madras and moved from one place to another within the specified areas even if only for the purpose of export the Tamil Nadu Timber Transit Rules would be applicable and the requirements of the rules will have to be satisfied. ( 13 ) NEXT, as regards the applicability of the Tamil Nadu Sandalwood Possession Rules the relevant provisions read as under : "3. Form and manner in which application for licence may be made. (1) No person shall possess or stock sandalwood in excess of five kilograms without a licence. Whenever any person intends possessing or stocking sandalwood in excess of five kilograms he shall apply to the District Forest Officer in Form I and obtain a license after paying the fees prescribed in sub-rule (7) of R. 4. Every application for the grant of a licence shall be accompanied by authenticated documents and other relevant particulars in support of the procurement of the sandalwood. Every application for the grant of a licence shall be accompanied by authenticated documents and other relevant particulars in support of the procurement of the sandalwood. (2) On receipt of the application together with the authenticated documents, the District Forest Officer shall if he is satisfied about the bona fides of the applicant issue a licence in Form II for the possession of sandalwood. (3) Whenever the dealer or stockists intends to obtain or procure possession of subsequent consignments of sandalwood, he shall immediately inform the District Forest Officer, in writing, of the actual source from which he intends obtaining such additional consignment of sandalwood and supply such information as the District Forest Officer may require, from time to time, to satisfy himself about the bona fide of such additional consignment of sandalwood. (4) Whenever the dealer or stockist comes into possession of a consignment of sandalwood, he shall within twenty-four hours, inform the District Forest Officer of the place of storage of sandalwood about the fact of possession and the same shall be inspected by an officer not below the rank of a Forester without any delay and till such inspection is over the dealer shall not tamper with the identification marks that may have been already placed on such sandalwood. (5) After such inspection, the dealer or stockists shall be given an order in writing by the District Forest Officer to convert such sandalwood, if such conversion is sought to bemade: Provided that the District Forest Officer may refuse to grant or renew a licence to any applicant or licensee if he has reason to believe that the information required is not given or that the person has been concerned in any legal practice with regard to sandalwood or for any other goods. " ( 14 ) RULE 2 (b) defines the term "dealer" and the definition reads as under : " (B) "dealer" means any person who carries on the business in Sandalwood of buying, - selling, supplying or distributing Sandalwood directly and includes: (i) a local authority or company which carries on business in sandalwood. (ii) an auctioner or his accredited agent, by whatever name called who carries on the business in sandalwood of buying, selling, supplying or distributing sandalwood on behalf of any principal, and (iii) every local branch of a firm or company situated outside the State;" ( 15 ) MR. (ii) an auctioner or his accredited agent, by whatever name called who carries on the business in sandalwood of buying, selling, supplying or distributing sandalwood on behalf of any principal, and (iii) every local branch of a firm or company situated outside the State;" ( 15 ) MR. Bhatia contended that R. 3 read along with the forms 1 and 2 contained in the schedule shows that the Tamil Nadu Sandalwood Possession Rules, 1970 apply to dealer or stockists who are carrying on business in sandalwood of buying, selling, supplying or distributing sandalwood. Mr. Bhatia contended that the Sandalwood Possession Rules would not be applicable to the timber in question since it was meant to be exported under a valid permit granted by respondents 2 and 3. 1 regret, I am unable to agree in this contention of the learned counsel. From the facts mentioned in the petition and noticed in the opening part of the judgment it is clear that the petitioner is dealing in the buying and supplying of sandalwood. The petitioner would come within the definition of dealer as given in R. 2 (b ). Even otherwise the opening words of R. 3 (1) put a bar on any person possessing or stocking sandalwood in excess of five kilograms without a licence. The petitioner on 6th December 1978 had purchased one tonne of sandalwood and had removed the same to Madras and placed it in the custody of M/s. Jayna and Co. for export from Madras port. The permit for export was obtained by the petitioner on 8th November 1979. The petitioner under the Tamil Nadu Sandalwood Possession Rules was legally bound to obtain a licence for storing the sandalwood with the shipping agents. ( 16 ) FOR the reasons stated I am of the view that both the Tamil Nadu Sandalwood Possession Rules and the Tamil Nadu Timber Transit Rules are applicable and the petitioner has to comply with them. ( 17 ) MR. Bhatia also referred to Man Mohan Tuli v. Municipal Corporation of Delhi, AIR 1981 SC 991 . For the reasons already stated I am of the view that this authority also is not applicable. Mr. ( 17 ) MR. Bhatia also referred to Man Mohan Tuli v. Municipal Corporation of Delhi, AIR 1981 SC 991 . For the reasons already stated I am of the view that this authority also is not applicable. Mr. Bhatia also contended that the Tamil Nadu Sandalwood Possession Rules and the Tamil Nadu Timber Transit Rules are violative of Art. 304 of the Constitution and, therefore, in so far as they seek to place restriction on the freedom of trade of the petitioner to that extent they are ultra vires of the Constitution. I do not agree in this contention. The impugned rules in no manner restrict the right of the petitioner to trade. The impugned rules only regulate the possession and the transit of the sandalwood within the State of Tamil Nadu. ( 18 ) RESPONDENTS 4 to 6, it seems, have instituted some criminal proceedings against the petitioner for the violation of the rules. The petitioner has also prayed for the quashing of the said criminal proceedings. 1 do not think it is competent to this Court to quash the criminal proceedings instituted against the petitioner in Tamil Nadu. ( 19 ) IT may be that the petitioner bona fide thinking that the Tamil Nadu Sandalwood Possession Rules and the Tamil Nadu Timber Transit Rules are not applicable had not moved the concerned authority for the grant of permit/licence. The petitioner is given the liberty to now move the concerned authority under the said rules for the grant of necessary permit/licence. If any application is made by the petitioner, the concerned authority shall dispose of the application within one month of the making of the application. ( 20 ) SHRI C. L. Chaudhary, learned counsel for respondents 1 to 3, has not opposed the petition regarding the prayer for a direction to respondents 1 to 3 to revalidate the licence for the export of sandalwood. Respondents 1 to 3 shall revalidate the licence for the export of the sandalwood. ( 21 ) TO be fair to the learned counsel for respondents 4 to 6 I may mention that he raised a preliminary objection that no part of the cause of action had arisen within the territorial jurisdiction of this Court, therefore, this Court had no jurisdiction to entertain the petition. I do not agree in this contention. ( 21 ) TO be fair to the learned counsel for respondents 4 to 6 I may mention that he raised a preliminary objection that no part of the cause of action had arisen within the territorial jurisdiction of this Court, therefore, this Court had no jurisdiction to entertain the petition. I do not agree in this contention. The export permit was granted by respondents 1 to 3 at Delhi. One tonne of sandalwood for export was sent from Delhi. From the statement of facts in the petition it admits of no doubt that part of the cause of action had arisen at Delhi and, therefore, this Court has jurisdiction to entertain the petition. ( 22 ) THE petition is disposed of accordingly. The parties, are, however, left to bear their own costs.