JUDGMENT - S.M. DAUD, J.:---Can company maintained rest houses or guest houses in Bombay with access restricted to visiting out station Officers and Directors be said to be "exclusively used as a private residential premises"? 2. The point formulated in the preface arises in the following background: The Bombay Electric Supply and Transport (BEST) is a Bombay Municipal Corporation (BMC) undertaking engaged in the supply of electrical energy to different classes of consumers. It is licensed to do so and is therefore a 'licensee' under the Indian Electricity Act, 1910 (EL Act). The rates chargeable to consumers are regulated by a tariff varied from time to time. Consumers are broadly classified by the purpose to which the energy supplied premises are put to. Category 'R' is the rate chargeable for energy used as a private residential premises. Abbreviation 'C' is the rate for energy used in non-industrial premises bar those specifically excluded. The State of Maharashtra has imposed a duty on units of energy consumed by different classes of consumers. Licensee collect the said duty along with their charge for energy supplied. The statute regulating the rates, collection and transmission is the Bombay Electricity Duty Act, 1958 (ED Act). Disputes as to liability and classification for rate of duty under this Act have to be resolved by the Electrical Inspector. 3. Petitioners are companies incorporated under the Indian Companies Act, 1956. They have a flat each in the city of Bombay means for use only by a select class of out-station employees and/or directors. Electricity supplied to these flats was billed at 'R' rates till sometime before the institution of the petition. The BEST changed the rate of "C", contending that the flats were not private residences. In respect of the past user, petitioners were called upon to pay the difference. Correspondence ensued and in one of its letters addressed to the petitioner in the 1981 petition, the BEST conceded that the rate at which electricity duty had been calculated was wrong. That company was asked to contact the Electrical Inspector for a refund of the amount paid in excess in the past. As to the tariff for billing energy consumed, the petitioners claim that they fall in the 'R' category. The BEST contends that it is "C" rates which are applicable to the flats figuring in the petitions. 4. That company was asked to contact the Electrical Inspector for a refund of the amount paid in excess in the past. As to the tariff for billing energy consumed, the petitioners claim that they fall in the 'R' category. The BEST contends that it is "C" rates which are applicable to the flats figuring in the petitions. 4. Sections 22 and 23 of EL Act relied upon by the petitioners forbid a licensee from discriminating between consumers of a like kind in the matter of charging them for the energy supplied. Ex. 1 annexed to the return in the 1981 petition is the classification of consumers for the purpose of levying a charge. The rates for the different classes change, but the categorisation since 1974 is constant Mr. Bharucha for the Company in 1981 petition contends that the use of premises by a company for its out-station visitors without this being a profit motivated venture cannot take the same out of the 'R' abbreviation. A private residence does not cease to be so because the identity or number of its occupants changes in short periods. The access to and use of the flats being restricted to a distinct and limited class, these flats are private residential premises. Counsel for the BEST disputes this submission, his argument being that the 'R' category envisages occupation by an individual or family who make the premises their home for a fairly long period to qualify for semi-permanency, if not permanency. This strict view is said to be made clear by the use of the words, "exclusively used as a private residential premises". Each words carried an emphasis, the effect of the whole being the limitation canvassed on behalf of the licensee. 5. Mr. Bharucha relies on the dictionary meaning of the word "private". In the Concise Oxford Dictionary some of the connotations given to the word use : "not open to the public; one's own; individual; personal". Again in the Chambers Dictionary the word is perceived as "belonging to, or concerning an individual or Company". But this cannot be the only factor to be considered for interpreting the words. There are other words such as 'exclusively used' "a", "residential premises" and all of them have a significance. Again in the Chambers Dictionary the word is perceived as "belonging to, or concerning an individual or Company". But this cannot be the only factor to be considered for interpreting the words. There are other words such as 'exclusively used' "a", "residential premises" and all of them have a significance. If the categorisation was to distinguish only between residential and non-residential or private and public users, the other words would not have found a place in the 'R' enumeration. A purpose has to be attributed to the detailed enumeration. It cannot be assumed that the author of the tariff indulged in verbiage. If premises used for any type of residence other than as a profit-making venture were to be in the 'R' abbreviation, the remaining words in the enumeration become redundant. The purpose could have been equally well served by use of lesser words. The stringing together of the many words has a purpose and it is that which has to be ascertained and this I proceed to do by recourse to the Chambers Dictionary. An important word in the formulation is the word comprised in the single letter 'a'. This includes' a class arbitrarily designated'. Then comes the word 'exclusively' preceding 'used'. The negative sense thereof is 'not included'. 'Residential' is equated to 'connected with residence'. 'Residence' means 'Act of dwelling in a place' as also 'a dwelling house'. The joining together of these many words militates against the interpretation canvassed for the petitioners. Exclusivity in the residential user of the premises is one fact. The other hand equally important facet is governed by the use of the qualifying word 'private'. Taken together with the other words the intent is to qualify the exclusive user for residential purposes with the character of privacy. This leads to the compelling conclusion that the 'R' category is restricted to premises used as private residences and by a fixed category e.g. a family whose occupation is permanent or at least of a duration dependent on factors such as length of service or posting at a place etc. It will not apply to cases where flats are provided for transitory periods for out-station officers and directors. Mr. Bharucha argues that this would give rise to a discriminatory approach as between persons similarly circumstances. It is not possible to look upon casual visitors and or permanent residents as an identical or single class. It will not apply to cases where flats are provided for transitory periods for out-station officers and directors. Mr. Bharucha argues that this would give rise to a discriminatory approach as between persons similarly circumstances. It is not possible to look upon casual visitors and or permanent residents as an identical or single class. They are different and the difference is overwhelming. The place of residence of the first is known as an 'inn', 'rest house', 'guest house' 'hostel' and 'hotel'. That of the other is a 'home'. Agreeing with Counsel for the respondents I hold that the placing of the petition premises in the residury 'C' category was justified. 5-A. Mr. Bharucha's client wants a refund of the excess admittedly charged towards duty. Respondents point to the ED Act which provide for an approach to the authority designated for this purpose . Mr. Bharucha submits that the excess duty was recovered by recourse to the threat of disconnection and this threat was given by the BEST. This contention has to be accepted. The BEST cannot compel wrong recoveries and then leave the consumers to the expense and trouble of getting back duty coercively recovered, from the State Government. The recourse to pressure was by the BEST and it is but fair that they be held liable for restituting the deprived consumer. 6. To sum up, the petitions in so far as they relate to chargeability for energy consumed as 'R' category, fail. Refund of duty recovered in excess will have to be allowed. Hence the order. 7. Respondent BMC do refund electricity duty charged in excess of that claimable as conceded in Ex. L (W.P. No. 539 of 1981) to the petitioners from whom so recovered. Rule in the two petitions to this limited extent made absolute with parties left to bear their own costs. Rule made absolute. -----