JUDGMENT - S.M. DAUD, J.:---Do Alpha Olefin (AO) and Alpha Olefin Sulphonate (AOS) used in the manufacture of detergents qualify as "other substances used in washing clothes, floors and utensils" occurring in Entry 18, Schedule H of the Bombay Municipal Corporation Act-hereinafter referred to as the "BMC Act"? 2. Petitioner No. 1-a Company- is in the business of manufacture of detergents. A raw material used in the said manufacture is AOS and this is created by neutralising and sulphonating the chemical AO. The resultant substance is known as sodium alpha olefin sulphonate. Mixed with organic and inorganic builders, it is used to manufacture detergent products taken recourse to in cleaning operations. Petitioner disputes the respondents' (BMC) treating the import of AO and AOS as leviable to octroi under Entry 18 of Schedule H which reads thus :--- "Potash, ritha, soda, alum, saline substances, shikekai, washing soda, caustic soda, refined salt-petre, phenyl, and substances used in washing clothes, floor and utensils." This entry course In Class III which is titled "Articles used for fuel, lighting, washing and industrial use." 3. A resolution of the controversy requires answers to two questions. First, what exactly are detergents and the two chemicals, and the second, which is the canon applicable for construction of Entry 18. A detergent broadly speaking is that which cleanses. The Chambers 20th Century Dictionary (New Edition 1983) gives to the word amongst amongst others at page 338, the being of 'solvent or mixture of solvents an certain water-soluble oils'; 'a soapless cleanser'. Mr. Bharucha, representing the BMC has relied upon the Random House Encyclopaedia and a condensed Chemical Dictionary to illuminate the path. From the Encyclopaedia we get the information that soap and detergents (the two terms being broadly synonymous) are cleansing agents. These are required because water by itself is incapable of easily getting rid of dirt and grease. Because of its high surface tension water runs off or stays put without penetration when poured on a greasy area. Therefore, the requirement of a cleansing agent that lowers surface tension which enables the water to penetrate and remove the dirt or grease. Synthetic detergents are mixtures of various ingredients, the chief of which is the cleansing agent or surfactant. The major raw materials for soap manufacture are fat and alkali. Therefore, the requirement of a cleansing agent that lowers surface tension which enables the water to penetrate and remove the dirt or grease. Synthetic detergents are mixtures of various ingredients, the chief of which is the cleansing agent or surfactant. The major raw materials for soap manufacture are fat and alkali. The Dictionary aforementioned shows a soap builder to be any material mixed with soap to improve the cleaning properties, modify the alkali content, or confer water-softening characteristics. Turn now to the date furnished by petitioners in the 1983 petition. Ex.G. is an excerpt from a trade bulletin issued - so it appears - by the manufacturers of product Sulfermin 14-16 AOS. The product is an AOS consisting primarily of 14 and 16 carbon chain distributions. It is suitable as an active base for general detergent products. The product is said to be in wide use for manufacture of different types of intermediates in the detergent trade. Safety measures have been prescribed for the handling of the product and the basic ones are use of gloves and chemical safety goggles. Even accidental contact of the product with the eyes is to be counteracted with immediate flushing by copious quantities of water. Ex.H-1 is an affidavit of Dr. Mungekar, a highly qualified Chemist. The affidavit says that AOS is a small part of the composition of detergents. By itself cannot be used a washing substance. Ex.H-2 is the affidavit of P.M. Batlivala, who is in the business of soaps and cosmetics for the last more than 15 years. He repeats the assertion that AOS is a small component of detergents. To the same effect is Ex.H.-3 an affidavit filed by G.H. Thakkar, who is in the business of manufacturing, and trading in chemicals required in the making of soaps and detergents. The above suffices to establish the conclusion that AO and AOS are used in the manufacture of detergents, that by themselves they cannot be so used and that the popular as also the cognoscente perception, is, that the chemicals by themselves are not washing substances. 4. This takes me to the second question. Petitioners press the popular or common sense rule of interpretation. This rule requires the giving of that meeting to an undefined word or expression which those in the trade give to it. 4. This takes me to the second question. Petitioners press the popular or common sense rule of interpretation. This rule requires the giving of that meeting to an undefined word or expression which those in the trade give to it. See (Atul Glass Industries v. Collector of Central Excise)1, 1986(25) E.L.T. 473 (S.C.), (Asian Paints India Ltd. v. Collector of Central Excise)2, 1988(35) E.L.T. 3 (S.C.), and (United Offset Process Pvt. Ltd. v. Asstt. Collector of Customs)3, 1988(38) E.L.T. 568 (S.C.) To put it in simpler language, the test is how the product is identified by the class or section of people dealing with or using the product. Indeed the trade meaning has been said to have preference over the dictionary meaning which is said to be 'not always safe' (Collector of Central Excise v. Krishna Carbon Paper Co.)4, 1988(37) E.L.T. 480 (S.C.). Mr. Bharucha, argues that words in Entry 18 have to be construed in a technical and scientific sense, for, so is the dictate of the context. Counsel relies on (Chemicals Fibres India Ltd. v. Union of India)5, 1982 E.L.T. 917 Bom. and (Akbar Badurddin Jiwani v. Collector of Customs)6, 1990(47) E.L.T. 161 (S.C.). Justice B.C. Ray, in the latter case has expressed the principle in these words :--- "There is no doubt that the general principle of interpretation of Tariff Entries occurring in a tax statute is of a commercial nomenclature and understanding between persons in the trade but it is also a settled legal position that the said doctrine of commercial nomenclature of trade understanding should be departed from in a case where the statutory content in which the Tariff Entry appears, requires such a departure. In other words, in cases where the application of commercial meaning or trade nomenclature runs counter to the statutory context in which the said word was used then the said principle of interpretation should not be applied. Trade meaning or commercial nomenclature would be applicable if a particular product description occurs by itself in a Tariff Entry and there is no conflict between the Tariff Entry and any other Tariff Entry requiring to be reconciled and harmonise that Tariff Entry with any other Entry." Counsel submits that barring an article or two in Entry 18, all others are chemicals used in the manufacture of what may be broadly described as cleansing products. Even those not so classifiable have a kinship to the operation of washing. The context becomes more distinct in the light of the class heading showing it to be a class of articles used in washing and industrial use. A scientific and technical context requires the use of the same glossary for decoding the words. 5. Mr. Bharucha, has used the Condensed Chemical Dictionary with great effect to establish his point. Alphabetically arranged the words in Entry 18 have the following meaning attributed to them in the above and other sources:--- 1. Alum-also known as ammonia-soluble in water-one of its uses being water and sewage purification. 2. Caustic Soda-Chemically knows as sodium hydroxide-said to be the most important commercial caustic-soluble in water. 3. Phenyl-described as an organic radical, found in benzene and phenol etc. Phenol is commonly known as a powerful disinfectant. 4. Potash-is the popular name of potassium hydroxide or caustic potash-it is a well known powerful alkali. 5. Ritha-soapberries-described in the Random House Encyclopaedia as tree fruits containing a Soapy substance called saponin. Ritha described as one of the primitive cleansers is no mystery to the Indian housewives-specially those, in and coming from the mofussil. 6. Saline substance-saline means salt, salty, of the nature of salt; of the salts of alkali metals and magnesium-substance like common salt, a plentiful raw material went into the making of alkali caustic soda freeing mankind from the earlier dependence on plant ashes for making of soap. 7. Refined salt-petre. The chemical name for salt-petre is potassium nitrate-soluble in water-one of its uses is as a reagent in analytic chemistry. 8. Soda-anyone of the forms of sodium carbonate. 9. Shikekai-a herbal concoction used for hair cleaning-specially by ladies. 10. Washing soda-used in preparation of material or directly for washing also. 6. Bar refined salt-petre, all the other articles are connected with the cleansing operation. The odd article may be treated as fit for industrial use. Ritha and Shikekai of their derivatives are used in the manufacture of soaps and shampoos. Phenyl' diluted is to be found in disinfectants as also medicated soaps. The other articles are all used in the manufacture of soaps, detergents and cleansing material whether in solid, liquid or crystal forms. After the enumerated articles come the words "and substances used in washing clothes, floors and utensils". The conjunctive and denotes a continuity with the proceeding words. Phenyl' diluted is to be found in disinfectants as also medicated soaps. The other articles are all used in the manufacture of soaps, detergents and cleansing material whether in solid, liquid or crystal forms. After the enumerated articles come the words "and substances used in washing clothes, floors and utensils". The conjunctive and denotes a continuity with the proceeding words. To counter the suggestion of petitioners that the words extracted above cover only products directly usable for washing purposes recourse is had to Entry 17 which covers "soap of all kinds". It is argued that substances directly usable for washing purposes are covered by Entry 17 and Entry 18 deals only with ingredients necessary for manufacture of washing products. The words "of all kinds" qualifying the word 'soap' in Entry 17 bears out this contention. In the Condensed Chemical Dictionary the word 'soap' has been explained to be of ordinary, common, special, hard, soft, liquid and metallic varieties. Common soap is said to be largely a mixture of the sodium salts of palmitic, stearic and oleic acids. Entry 17 would thus cover almost all products readily usable for washing purposes. Having so done, it would be an incongruity to impute to the legislature an intent to repeat itself while framing Entry 18. A well-known caution of interpretation is that the legislature does not indulge in surplusage. To recapitulate, the context read together with the caution aforementioned indicates the adoption of the scientific or technical meaning. Apart therefrom is the rule of ejusdem generis which is attracted here. As indicated by the analysis of Entry 18, the specified articles mentioned therein can be 'broadly classified as those used in the manufacture of cleansers inclusive of purifiers. This understanding is not diminished by looking at the articles in the light of the class heading for the same covers articles used for washing as also industrial use. Articles used in industry engaged in the manufacture of "soaps of all kinds" would be deemed covered by the last eight words of Entry 18. This inference is strengthened by the conjunctive and, preceding the last eight words and succeeding the enumerated words of the entry. The 'and' limits the width of the succeeding words. The principle of ejusdem generis has been thus explained by Venkatachaliah J., in (M/s. Siddeshwari Cotton Mills (P). This inference is strengthened by the conjunctive and, preceding the last eight words and succeeding the enumerated words of the entry. The 'and' limits the width of the succeeding words. The principle of ejusdem generis has been thus explained by Venkatachaliah J., in (M/s. Siddeshwari Cotton Mills (P). Ltd. v. Union of India)7, A.I.R. 1989 S.C. 1019:--- "The expression ejusdem generis 'of the same kind or nature'-signifies a principle of construction whereby words in a statute which are otherwise wide but are associated in the text with more limited words are, by implication, given a restricted operation and are limited to matters of the same class or genus as preceding them. If a list or string or family of genus describing terms are followed by wider or residuary or sweeping-up words, then the verbal context and the linguistic implication of the preceding words limit the scope of such words ....... The preceding words in the statutory provisions which, under this particular rule of construction, control and limit the meaning of the subsequent words must represent a genus or a family which admits of a number of species or members. If there is only one species it cannot supply the idea of a genus." Applying the above criteria, it is clear that the last few words of Entry 18 do not envisage finished products, but ingredients usable in the manufacture of such products. These would not exclude AO and AOS. 7. The petition fail. Rule granted in the two petitions is hereby discharged. Interim relief to stand revoked and bank guarantees furnished shall be enforceable as from the expiry of six weeks from today. Rule discharged. -----