Judgment :- Jagannadha Rao, c.j. This Writ Appeal is preferred against the judgment of the learned Single Judge in O.P.No. 9123 of 1988 dated 1.3-11-1992. By that judgment, the Writ Petition filed by the appellant was dismissed. 2. The point raised in this Writ Appeal deals with the validity of levy of contribution under the Wakf Act, 1954, as amended by Kerala Act 18 of 1972. The appellant-writ petitioner is the Pcrumpadappu Puthanpalli. Jaram, Madrassa and Hospital Paripalana Committee, Perumpadappu. This is a famous shrine in Malappuram District in Kerala, where the remains of a muslim saint were laid to rest, and the shrine attracts large number of devotees and pilgrims from all over the country. The collection of the institution as disclosed from Ext. P1 order of the Kerala Wakf Board dated 30-4-1987 will give an indication of the large number of devotes and pilgrims who visit the shrine every year. Ext. P1 order shows that the income of the shrine was Rs. 20 lakhs in 1979-80, Rs. 28 lakhs in 1980-81, Rs. 49 lakhs in 1981-82, Rs. 49 lakhs in 1982-83, Rs. 53 lakhs in 1983-84, Rs. 54 lakhs in 1984-85 and 1985-86, and so on. The Wakf Board issued a show cause notice with regard to the collection of contribution under S.46 and aftcr giving opportunely to the pchlioner passed Ext. P1 order dated 30-4-1987. That order deals with various amounts, including levy of contribution on the jaram collection. The order says that jaram collections are liable for contribution. Three reasons are given in this order. The first one is that this part of the income does not come under voluntary contributions, inasmuch as every devotee has in his mind some purpose for which the offering is made in money. The second reason given was that only small amounts could be contribution, but not large amounts which amount to lakhs of rupees. The third reason is that the petitioner received auction amount from the auction purchaser for the right to collect contributions or offerings and therefore the same cannot be treated as voluntary contribution or offering. The petitioner applied for reconsideration as per Ext. P2 representation dated 4-6-1987, and it was not accepted, and a fresh demand was made on 29-12-1987 as per Ext. P3. Thereafter the demand notice was issued under Ext. P4 dated 14-10-1988. The petitioner applied for reconsideration on 28-10-1988 as per Ext. The petitioner applied for reconsideration as per Ext. P2 representation dated 4-6-1987, and it was not accepted, and a fresh demand was made on 29-12-1987 as per Ext. P3. Thereafter the demand notice was issued under Ext. P4 dated 14-10-1988. The petitioner applied for reconsideration on 28-10-1988 as per Ext. P5 and the same was rejected and a fresh demand was issued as per Ext. P6 dated 4-11-1988 for a sura of Rs. 19,37,634.55. 3. Questioning the above said orders, Ext. P1 and the demands, Ext. P4 and P6, the writ petition was filed in 1988. The learned Single Judge dismissed the Writ Petition. Against the said judgment, this appeal is preferred. 4. For the purpose of appreciating the contentions of the petitioner, we have to go by S.46 of the Wakf Act, 1954, before its amendment in 1984. By virtue of 1984 amendment, the definition of 'net annual income' was shifted below Explanation to S.46. But we are not concerned with the same. We are concerned here with the definition of 'net annual income' in S.3(g) of the 1954 Act as it stood originally and as substituted by Act 38 of 1969. 5. By virtue of 1984 amendment, the definition of 'net annual income' was shifted below Explanation to S.46. But we are not concerned with the same. We are concerned here with the definition of 'net annual income' in S.3(g) of the 1954 Act as it stood originally and as substituted by Act 38 of 1969. 5. Section 3(g) of the Central Act defines 'net annual income' as follows: "S.3(g) "net annual income', in relation to a wakf, means the gross income thereof from all sources in a year excluding only - (i) land revenue, cess, rates and taxes payable to the Government or any local authority; and (ii) donations given or offerings made with a specific direction that they shall form part of the corpus of the wakf; Provided that the interest or income, if any, accruing from such donations or offerings shall be taken into account in calculating the gross annual income." By the Kerala Amendment Act 18 of 1972, three sub-clauses were added below the two sub-clauses of the above said S.3(g) as follows: "(iii) income accruing to the wakf from pidiyari, kettuthengu and similar other voluntary contributions in kind or in cash; (iv) grants received from the State Government for the purpose of institutions such as mosques, orphanages, madrassas, schools and colleges; and, (v) donations given by the public for the purpose of maintenance of orphanages or inmates I hereof and Madrassas and Arabic Colleges." At the time of introducing the above said Amendment in 1972 in Kerala, the Minister, who introduced the bill, made the following statement: "The object of this bill is very limited and clear. The law is that a contribution up to 6% from the collections for the management of oulads is to be given as contribution to the Wakf Board for the Board's expenses. This is a law coming in the concurrent list. As a result of some amendments made by the Centre, even from collections from such as kettu tliengu, pidiyari, box collections, etc., which certain Madrassas and Masjids are making to meet the expenses of payment of salaries of employees, contributions are to be made to the Wakf Board, and on account of this oulads are suffering difficulties. As a result of some amendments made by the Centre, even from collections from such as kettu tliengu, pidiyari, box collections, etc., which certain Madrassas and Masjids are making to meet the expenses of payment of salaries of employees, contributions are to be made to the Wakf Board, and on account of this oulads are suffering difficulties. Therefore in the last Assembly Session, a bill had been prepared considering the difficulty of oulads and intent to exempt from the scope of contribution to the Wakf Board such small contributions collected for the upkeep (maintenance) of these institutions. Since that bill could not be introduced in the last Assembly Session before it was suddenly prorogued, an ordinance was passed. A statement regarding the circumstances which necessitated that ordinance was placed before the Assembly few minutes back. In the paragraph giving the objects of the Bill, all facts are clearly stated. Hence I now propose only to appeal to the Assembly to pass the Bill very soon." 6. The contention in the Writ Petition is that the petitioner-trust was receiving various contributions or donations by the pilgrims and devotees and the said contributions or donations come within the exclusionary clauses in S.3(g) of the Act. The contention raised is mainly based upon Kerala Amendment in sub-clauses (3) and (5). It is contended that the contributions or donations made by the pilgrims and devotees come within the later part of sub-clause (iii), inasmuch as they are 'similar other voluntary contributions in kind or in cash'. It is also contended that these will come under sub-clause (v), inasmuch as they are donations given by the public for the purpose of maintenance of orphanages or inmates thereof and Madrassas and Arabic Colleges. For the purpose of appreciating the above contention, it will be necessary to read the definition of 'net annual income' in S.3(g) as a whole and then find out what is meant by 'gross income' and what is meant by the exclusionary clauses, and in particular sub-clauses (3) and (5). 7. The main part of S.3(g) defines 'net annual income' as meaning gross income thereof from all sources in a year excluding what is mentioned in sub-clauses (1) to (v). The words 'from all sources' would mean that whatever manner in which the income Is received by the trust constitutes the gross income and is to be initially taken into account and computed. The words 'from all sources' would mean that whatever manner in which the income Is received by the trust constitutes the gross income and is to be initially taken into account and computed. Out of the said total income or gross income, certain items mentioned in clauses (i) to (v) are to be excluded. Under sub-clauses (i) certain items such as land revenue, cess, rates and taxes payable to the Government or any local authority are excluded. Under sub-clause (ii) donations given' or offerings made with a specific direction that they shall form part of the corpus of the wakf are excluded. Under sub-clause (3) income accruing to the wakf from pidiyari, kettuthcngu and similar other volmilary contributions in kind or in cash is to be excluded. Under sub-clause (iv) grants receive! from the State Government for the purpose of institutions such as mosques, orphanages, Madrassas, Schools and colleges arc excluded. Under sub-clause (v) donations given by the public for the purpose of maintenance of orphanages or inmates thereof and Madrassas and Arabic Colleges are excluded. In other words, out of the total income from all sources, the income mentioned in sub-clauses (i) to (v) has to be excluded for the purpose of arriving at'net annual income'. The legislature has used the words 'donations or offerings' in sub-clause (ii) and it has used the words 'voluntary contributions' in sub-clause (iii) and has again used the word 'donations' in sub-clause (v). According to the ordinary principles of interpretation of Statutes, it must be taken that the Legislature has deliberately used the words 'donations or offerings' in sub-clause (ii) as being distinct from Voluntary contributions' in kind or cash' in sub-clause (iii). 8. Learned counsel for the petitioner has contended that the learned Single Judge was wrong in holding that the various amounts given by the pilgrims and devotees are offerings and not voluntary contributions in cash. In this context, it has to be noticed that out of the total gross income from all sources donations given or offerings made are excluded, under sub-clause (ii), only if they are given or made with a specific direction that they shall form part of the corpus of the wakf. In this context, it has to be noticed that out of the total gross income from all sources donations given or offerings made are excluded, under sub-clause (ii), only if they are given or made with a specific direction that they shall form part of the corpus of the wakf. In other words, if the donations given or offerings made, which come under sub-clause(ii) of S.3(g), are not given or made with a specific direction that they shall form part of the corpus of the wakf, then they shall necessarily be 'net annual income' coming from one of the sources, and inasmuch as such donations or offerings are not given with a specific direction that they shall form part of the corpus of the wakf, they are not excluded. When we come to sub-clause (iii) the question is what is meant by 'pidiyari' or 'kcltuthengu', for we have to give meaning to the word similar occurring after the words' income accruing to the wakf from pidiyari, kcttuthengu'. Pidiyari is said to be an offering of rice of a handful, which is meant to be used for the purpose of serving food to devotees or pilgrims who visit the shrine. Kellulhengu is said to be the value of the coconuts or the coconut farm trees which a devotee or pilgrim would give to the shrine for the purpose of being utilized towards' expenditure for the pilgrims and devolves who come to the shrine. Therefore th words 'similar other voluntary contributions in kind or in cash 'must also be considered to refer to cash contributions voluntarily made for the purpose of meeting the managerial or day-to-day expenditure of the shrine towards the devotees or pilgrims who come to the shrine. Ins/act, the Explanation given by the Minister on the Floor of the House would show that inasmuch as even such contributions which are meant to cater to the day-to-day expenditure of the shrine are being subjected to contributions, the institutions were suffering, and the fore for the purpose, the amendment was introduced for excluding such contributions which wen; made by the pilgrims or devotees for rneeting the day-today expenditure of the pilgrims or devotees who come to the shrine. Therefore out of the donations given or offerings made which form part of the net annual income under S.3(g) and which are not made with a specific direction that they shall form part of the corpus of the wakf as in sub-da use (ii) of S.3(g), only that part of donations or offerings which arc intended as contributions towards the expenditure for catering to the needs of the pilgrims and devotees are excluded under suh-clausc (iii), In other words, the income coming under sub-clause (iii) is of a specific and limited nature, and is not wide enough to cover the entire donations or offerings made by the devotees towards the trust. Therefore the contention of the petitioner that all donations given and offerings made in whatever manner they were made would come under sub-clause (iii) has to be rejected. No specific case was made out that She entire offerings amounting to several lakhs of rupees were contributed by the pilgrims or devotees to meet the day-to-day expenditure towards the food, etc., of the pilgrims or devotees coming to the shrine, so as to fall under sub-clause (iii). We therefore reject the contention under sub-clause (iii). 9. Coming to sub-clause (v), the burden of proof is on the petitioner to show that any donations given by the devotees or pilgrims was specifically intended for the maintenance of orphanages or inmates thereof and Madrassas and Arabic Colleges. Learned counsel for the petitioner fairly submitted that no case was presented before the Wakf Board under sub-clause (v), but a case was presented only in regard to later part of sub-clause (iii). Inasmuch as there was no such specific plea before the Wakf Board for exclusion of the donations, if any, made under sub-clause (v) of S.3(g), the argument based on the sub-clause must necessarily fail. For the aforesaid reasons, this appeal is liable to be dismissed, though for reasons different from those given by the learned Single judge, and it is accordingly dismissed. It will be for the appellant if there is any hardship to pay the amount in lump sum to apply to the Wakf Board seeking installments, if any, and it will be for the Wakf Board to consider whether there is any justification for granting instalments.