JUDGMENT M.N. RAO, C.J.—This writ petition concerns the constitutionality of the notification issued by the Government of Himachal Pradesh, respondent No. 1 herein, on 24-3-19925 amending the ninth proviso to the notification issued earlier on 29-5-1974 in consequence of which the rate of tax on quilt was increased from 2 paise in a rupee to 8 paise, The petitioners are registered dealers under the Himachal Pradesh General Sales Tax Act 1968 (hereinafter referred to as the Act) carrying on business in "bedding articles" besides cloth and cotton. The general rate of tax under Section 6 of the Act is 8 per cent other than the goods in respect of which by separate notification lower rate of tax was prescribed. The State Government on 1-4-1969 issued a notification prescribing tax at the rate of 2 percent on "ready-made sewn garments made out of handloom or mill made cloth excluding fur coats and garments prepared out of pure silk cloth but including um-beralla cloth covers and pillow covers except when made out of pure silk cloth, shall be two paise in a rupee." The tax authority assessed the turn-over relating to quilt or Razai at the higher rate of 8 per cent on the view that the aforesaid notification did not comprehend the quilts or Razais. The question was eventually resolved by a Division Bench of this Court in Sales Tax Reference No. 1 of 1986 dated 8-1-1991 by which it was held that the quilt or Razai is a ready-made sewn garment and, therefore, "would clearly fall under the notification aforesaid and qualify for concessional rate of tax under the notification." 2. Subsequently, on 24-3-1992 an amendment was issued in order to take away quilts or Razais from the concessional rate of tax of 2 per cent. By inserting the amendment at the appropriate place, the notification reads : "the rate of tax on readymade sewn garments (excluding quilt) made out of handloom or mill-made cloth excluding fur coats and garments prepared out of pure silk cloth but including umbrella cloth covers and pillow covers except when made out of pure silk cloth shall be two paise in rupee." 3. The petitioners are attacking the constitutionality of this notification on the ground that the classification made between quilt and other "ready-made garments" for the purpose of differential rate of taxation is arbitrary being violative of Article 14 of the Constitution. 4. The petitioners are attacking the constitutionality of this notification on the ground that the classification made between quilt and other "ready-made garments" for the purpose of differential rate of taxation is arbitrary being violative of Article 14 of the Constitution. 4. Shri M.M. Khanna, learned counsel for the petitioners has argued that the earlier Division Bench Judgment of this Court in Sales Tax Reference No. 1 of 1986 dated 8-1-1991 has finally concluded the question that quilt is a ready-made sewn garment and any attempt to further classify ready mads sewn garments for the purpose of subjecting the same to different rates of taxation is fore bidden by the equal protection clause enshrined in Article 14 of the Constitution of India, Quilt is nothing but cotton stuffed in cloth bag and when the cotton and the cloth are separated, cotton being declared goods under Section 14 of the Central Sales Tax Act, 1956, the tax in respect of which shall not exceed 4 per cent as mandated by Section 15 of the Act and cloth is a tax-free item. 5. Controverting these contentions, Shri M.S. Guleria, learned Deputy Advocate-General has urged that the State has wide discretion to subject different goods at different rates of tax and there is no warrant for the proposition that all ready-made sewn garments should be subjected to uniform rate of tax. Article 14 of the Constitution which guarantees equal protection of laws does not deprive the State of its power to pick and choose different varieties of goods for different rates of taxation. Although quilt is a ready-made sewn garment, it has distinct characteristics concerning manufacture, price and the user. So long as all the quilts of the same nature of manufacture are subjected to the same rate of taxation, as has been done in the present case, the action of the State cannot be challenged successfully. In his submission, although cloth and cotton are components of quilt, the latter cannot be treated either as cotton or cloth for the purpose of taxation. Cotton and cloth have lost their original identity when quilt is manufactured : quilt being the resultant product it alone is liable to tax qua quilt but not either as cotton or cloth. 6. We shall now consider the respective contentions. 7. Cotton and cloth have lost their original identity when quilt is manufactured : quilt being the resultant product it alone is liable to tax qua quilt but not either as cotton or cloth. 6. We shall now consider the respective contentions. 7. There is no doubt, whatsoever, that quilt is a ready-made sewn garment, it «s an article of clothing and clothing includes, inter alia, blankets and quilt being a kind of blanket with different kind of manufacturing process involved, it answers the description of a garment. This issue was concluded, as already stated supra, by the judgment of the Division Bench of this Court in Sales Tax Reference No. 1 of 1986. The question for our consideration Is not whether quilt is a ready-made garment, but whether there could be sub-classification among the ready-made garments for the purpose of subjecting the same to different rates of taxation. In other words, whether quilt could be treated as a separate item of taxation different from the other ready-made sewn garments. 8. Article 14 of our Constitution incorporates the English concept of equality before law and the American concept of equal protection of laws. In many a public law adjudication the root argument centres round Article 14; its horizons are ever expanding and the last word is yet to be said. The 14th amendment of the American Constitution incorporating the equal protection clause was explained by Justice Field of the American Supreme Court. It implies not only that every individual shall have access to the security afforded by laws but also that "no one shall be subject to any burdens or charges than such as are imposed upon all others under like circumstances". County of Santa Clara v. S. Pacific R.R. Co., 18 Fed. Rep 385, quoted in "Willoughby on the Constitutional law of the United States", Vol. 3, page 1948. In America despite this equal protection clause wide lattitude is given to the Legislature in matters of taxation. County of Santa Clara v. S. Pacific R.R. Co., 18 Fed. Rep 385, quoted in "Willoughby on the Constitutional law of the United States", Vol. 3, page 1948. In America despite this equal protection clause wide lattitude is given to the Legislature in matters of taxation. Professor Willoughby described the position thus: " while the Legislature may, within its discretion, determine freely what occupations, or classes of property or persons are to be taxed, It may not select out from the general mass of property, or general citizen body, particular pieces of property or particular individuals to bear the burden of the tax When, therefore, a tax is laid upon certain classes of property or of persons, there must be some reasonable basis for the classifications adopted. By this is meant that there must be some substantial reason why the units, whether of property or of individuals, should be treated as distinct groups." 9. "The reasonable basis for the classification" by judicial interpretation, attained a wider connotation in the United States of America. Examining the position with reference to the decisional law, Professor Rottschaefer reached the conclusion : "The decisions of the Supreme Court in this have permitted a State Legislature to exercise an extremely wide discretion in classifying property for tax purposes so long as it refrained from clear and hostile discrimination against particular persons or classes". [Handbook of American Constitutional law by Henry Rottschaefer, 1939 Edn, page 669.] The conclusion reached by him is that: "The equal protection clause permits a State to tax the same kind of property of different classes of tax payers by different methods. 10. By the year 1972, the ambit of constitution standard with reference to the power of the State taxation was enlarged to a very great extent with the result that no State action so long as it. "rationally furthers a legitimate State purpose or inter est" would be voided. 36 L Ed 2d 16 at p 56. 11. The test for determining the constitutionality of a tax saw was laid down by Chief Justice Warren in McGowan v Maryland 6 L Ed. 2d 393 : "The constitutional safeguard is offended only if the classification rests on grounds wholly irrelevant to the achievement of the States objective. The State legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality. 2d 393 : "The constitutional safeguard is offended only if the classification rests on grounds wholly irrelevant to the achievement of the States objective. The State legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality. A statutory discrimination will not be set aside if any state of facts reasonably may be conceived to justify It." 12. Following that dictum, Justice Stewart in San Antonios case, in a separate but concurring judgment opined that unless a conclusion is "wholly arbitrary or capricious" it would not be struck down as violative of the equal protection clause: "Unlike other provisions of the Constitution, the Equal Protection Clause confers no substantive rights and creates no substantive liberties. The function of the Equal Protection Clause, rather, is simply to measure the validity of classifications created by State laws. There is hardly a law on the books that does not affect some people differently from others". [36 L Ed 26 16 at p. 58.] 13. The legal position in India is no different from the United States in regard to the taxation power. If a tax law promotes a State purpose which is not legitimate, it attracts the inhibition of the equal protection clause as was the case in Metropolitan Life Insurance Company v. W.G. Ward, [84 L Ed. 2d 751] in which an Alabama statute, which imposed substantially lower rates of tax on domestic Insurance Companies and higher rates of tax on foreign insurance companies was struck down by a majority of five against four on the ground that "promotion of domestic business by discriminating against non-resident properties is not a legitimate State purpose". 14. The ratio in San Antonio was quoted with approval by our Supreme Court in Venkateshwara Theatre v. State of Andhra Pradesh, [(1995) 96 S.T.C 113 at p. 146.] 15. 14. The ratio in San Antonio was quoted with approval by our Supreme Court in Venkateshwara Theatre v. State of Andhra Pradesh, [(1995) 96 S.T.C 113 at p. 146.] 15. In support of the contention that the exclusion of quilt from the category of ready-made sewn garments for the purpose of subjecting the same to higher rate of taxation is arbitrary and there is no nexus with the object sought to be achieved, Shri Khanna, learned counsel for the petitioners, has relied upon the decision of the Supreme Court in Ayurveda Pharmacy and another v. State of Tamil Nadu, [(1989) 2 SCC 285 one ruling of the Madhya Pradesh High Court in General Foods Private Limited y. Commissioner of Sales Tax, [(1987) 66 S T.C. 271] and another ruling of Karnataka High Court in Kamat & Co and other v. State of Karnataka and another, [(1991) 80 ST.C. 226]. Contending that these rulings do not justify Interference by this Court, Shri Guleria, learned Deputy Advocate-General has cited SB. Dayai v. State of U.P., [AIR 1972 SC 1168,] Hire Lal Rattan Lal v. S.T.O. Section III, Kanpur, [AIR 1973 SC 1034,] Ayurveda Pharmacy and another v. State of Tamil Nadu, (1989) 2 SCC 285, State of Tamil Nadu v. Pyare Lal Malhotra, [AIR 1976 SC 800,] National Fire Works Factory v. D.C.7.O., [(1973) 31 S.T.C. 132] and M/s. Babu Ram Jagdish Kumar v. State of Punjab, AIR 1979 SC 1475. 16. After considering the rival submissions and examining the precedents cited, we are of the view that the impugned notification does not suffer from any legal or constitutional infirmity, 17. Although quilt is a ready-made sewn garment, the Government has ample power to subject it to a different rate of taxation. Among the classes of ready-made sewn garments, the Government has wide discretion to pick and choose different varieties of garments for subjecting them to different rates of taxation. The principle of equal protection of laws only enjoins that like should be treated alike. If among the categories of goods answering the description of quilt had the Government introduced different rates of taxation, it would have attracted the vice of Article 14. But that is not the case here. Quilt has distinct characteristics, different from other garments like trousers, shirts, coats, etc. It is costlier compared to other varieties of ready-made garments. If among the categories of goods answering the description of quilt had the Government introduced different rates of taxation, it would have attracted the vice of Article 14. But that is not the case here. Quilt has distinct characteristics, different from other garments like trousers, shirts, coats, etc. It is costlier compared to other varieties of ready-made garments. Its manufacturing process as well as the nature of its user are distinct and different as compared to other varieties of ready made garments. In the circumstances interference by this Court with the impugned notification would amount to denying the State its legitimate power to select different items for different rates of taxation. Article 14 is not intended to bring about uniformity in matters of taxation despite the fact that in judging the constitutionality of tax laws, its application is not excluded, 18. Depending upon the user, the same goods could be subjected to different rates of tax at the hands of different dealers and such a measure would not suffer from any infirmity on the ground of discrimination. Tobacco in its different forms could validly be brought to tax at different rates, was the view expressed as far back as 1982 in Jagan Nath v. Union of India, [AIR 1062 SC 148.] 19. Reiterating the well-known constitutional standard for judging the validity of taxation laws with reference to Article 14, the Supreme Court In East India Tobacco Company v. The State of Andhra Pradesh and another, [(1982) 13 SXC. 529,] after citing the celebrated passage from Willis on Constitutional law at page 587 that A State does not have to tax even/thing in order to tax something. It is allowed to pick and choose districts, objects, persons, methods, and even rates for taxation if it does so reasonably. ..." sustained Act 14 of 1955 enacted by the State of Andhra under which sales of Virginia tobacco were brought to tax, but sales of country tobacco were exempted, The argument based on discrimination emanating from the equality clause of Article 14 of the Constitution was rejected on the ground that differences exist between the Virginia tobacco and country tobacco and those differences were sufficient to treat Virginia tobacco as forming a class by itself for the purpose of taxation. The differences as found by the High Court and sustained by the Supreme Court are "taste, light colour and texture, nomenclature process of growing, curing and grading, market facilities foreign and inland, price and variety of uses." 20. If the object of the tax is within the legislative competence and there is no dispute that the impugned notification Is certainly within the ambit of the powers of the Government, there can be no legal impediment for subjecting the same to tax in order to raise higher revenue. The power to tax persons and property is an essential activity of the Government and this can be applied to the utmost extent to which the Government thinks it expedient to do so. [AIR 1863 SC 1667 at P. 1673.] 21. It is not for this Court to lay down any guidelines as to what objects should be brought to tax, the rates at which they should be subject to tax and the method by which the tax administration shall be carried on. This aspect was put beyond any doubt by the Supreme Court in S.B. Dayal v. State of U.P., AIR 1972 SC 1168 at Page 1169, “Though a tax is levied primarily for the purpose of gathering revenue, in selecting the objects to be taxed and in determining the rate of tax, various economic and social aspects such as the availability of the goods, administrative convenience, the extent of evasion, the impact of tax levied on the various sections of the society, etc. have to be considered. the power to tax must be a flexible power. It must be capable of being modulated to meet the exigencies of the situation," 22. In Hira Lal Rattan Lal v. The Sales Tax Officer, Section III, Kanpur (supra), the question for consideration was whether a law enacted by the U.P. Legislature to tax cereals and pulses as a separate item of foodgrains quite independent of the unprocessed and unsplit foodgrains, was in breach of Article 14 of the Constitution ? The contention based on impermissible classification was rejected by the Supreme Court: "The power of the Legislature to specify the nature of the goods the sale or purchase of which, it will bring to tax is very wide___ The classification between the processed or split pulses and unprocessed and unsplit pulses is a reasonable classification. The contention based on impermissible classification was rejected by the Supreme Court: "The power of the Legislature to specify the nature of the goods the sale or purchase of which, it will bring to tax is very wide___ The classification between the processed or split pulses and unprocessed and unsplit pulses is a reasonable classification. It is based on the use to which those goods can be put. Hence in our opinion, the impugned classification is not violative of Article 14." 23. No discrimination was found in the levy of tax on sale of cooked food in posh hotels and restaurants and exemption from such tax in respect of sales in modest eating places, by the Supreme Court in Kerala Hotel and Restaurant Association and others v. State of Kerala and others, 1990 (77) S.T.C. 253 where the legality of the impugned provisions of the Kerala General Sales Tax Act was sustained. Speaking for the three-Judge Bench, which decided the case, Justice J.S. Verma, (as he then was) observed : "The object apparently is to raise the needed revenue from this source by taxing the sale of cooked food only to the extent necessary and, therefore, to confine the levy only to the costlier food. The predominant object is to tax sale of cooked food to the minimum extent possible, since it is a vital need for sustenance." 24. Reliance was also placed in the above case on the observations made by the Supreme Court in P.M. Ashwathanarayana Setty v. State of Karnataka, (1989) Supp. 1 SCC 696, in which it was held : "If two or more methods of adjustments of an economic measure are available, the legislative preference in favour of one of them cannot be questioned on the ground of lack of legislative wisdom or that the method adopted is not the best or that there were better ways of adjusting the competing interests and claims. The Legislature possess the greatest freedom in such areas...." 25. If the taking Statute subjects some persons or objects to tax and leaves others, the same would not suffer from any Constitutional infirmity was highlighted in Mis. Jaipur Hosiery Mills Pvt. Ltd., etc. v. The State of Rajasthan and others, etc., AIR 1971 SC 1330, in which the notification issued by the State of Rajasthan exempting from sales tax on hosiery products, the value of which did not exceed Rs. Jaipur Hosiery Mills Pvt. Ltd., etc. v. The State of Rajasthan and others, etc., AIR 1971 SC 1330, in which the notification issued by the State of Rajasthan exempting from sales tax on hosiery products, the value of which did not exceed Rs. 4/- in a single piece, but subjecting the other hosiery products falling outside that limit, was challenged. The Court ruled : "It is for the State to decide while granting the exemption by means of a notification as to the class of goods which should be exempted in public interest. It is entirely for the taxing authorities to take a decision as to the goods which will be subjected to taxation and those which would be exempted from it." 26. Tested in the light of the ratio decen dendi of the precedents adverted to supra, in our considered opinion, the conclusion is inescapable that the impugned notification does not suffer from the vice of arbitrary classification fore bidden by Article 14 of the Constitution. In order to pass muster as constitutionally permissible classification under Article 14, the essential prerequisites are : (1) there should be intelligible differential between the objects grouped together from those left out for differential treatment, and (2) there should be nexus between the classification and the object sought to be achieved. Quilt is a garment used in winter for protection from the cold. It consists of two layers of cloth and cotton inserted between the two and firmly stitched. It is ordinarily of the size of a blanket and used for covering the body from the severity of the weather in winter. Although it may be called a garment with reference to dictionary meaning as was held by this Court in Sales Tax Reference No. 1 of 1986, in many respects it differs from other ready-made garments. It is much more costlier compared to other ready-made garments like trousers, shirts, shorts, waistes, baniyans, etc. We are told that its price range is Rs. 500/- and above. Its manufacturing process differs radically from the other varieties of ready-made garments. It is not used in all seasons and its use is confined only to the winter season unlike the other kinds of ready-made garments, which are used throughout the year. We are told that its price range is Rs. 500/- and above. Its manufacturing process differs radically from the other varieties of ready-made garments. It is not used in all seasons and its use is confined only to the winter season unlike the other kinds of ready-made garments, which are used throughout the year. Ready-made garment like quilt, therefore, can validly be classified separately from other ready-made garments as there is intelligible differentia between it and other varieties of garments. Those who purchase quilt, it being a costilier garment, can afford to pay the tax at higher rate. The object sought to be achieved by this classification is to raise more revenue and thus there is nexus between the classification and the object sought to be achieved. 27. Raising of revenue by the Government by resorting to taxation cannot be faulted when the law in that regard does not suffer from any kind of invalidity. The wisdom behind the present action of the Government to collect higher rate of tax at 8 per cent from the sales of quilts and exempting other categories of ready-made garments is a matter of policy beyond the purview of inquiry by this Court. Even if a Constitutional Court were to be of the opinion that resorting to taxation could have been done in a better manner, it would never be a circumstance justifying interference by way of judicial review. "The urgent need for revenue by the various governmental agencies," as observed by Professor Willis, is always a justifiable reason for according judicial assent, if otherwise such a measure does not suffer from any legal infirmity. 28. If Virginia tobacco could be brought to tax and country tobacco exempted as was the case in East India Tobacco Companys case (supra), hosiery garments sold at the rate not exceeding Rs. 4/- for single aricle could validly be exempted from taxation as was the case in M/s Jaipur Hosiery Mills Pvt. Ltd. (supra), there can be absolutely no justifiable reason to fault the present impugned notification by which quilt is treated differently from other kinds of ready-made garments. 29. The rulings cited for the petitioners, we think, do not advance their case. 29. The rulings cited for the petitioners, we think, do not advance their case. In Ayurveda Pharmacy and another v. State of Tamil Nadu (supra) subjecting Arishtams and Asavas which contain high percentage of alcohol at the rate of 30 per cent while bringing to tax other medicinal preparations at the lower rate of 7 percent, was held to be discriminatory. The only ground on which the higher rate of tax was imposed in respect of the two Ayurveda preparations in question was that "they contained a high percentage of alcohol and could be used as ordinary alcoholic beverages." This reason was held to be not a justifiable one in the face of the finding that those subjected to higher rate of tax and the others to lower rate of tax belong to the same category and if two commodities belong to the same category, there must be a rational basis for discriminating the one from the other for the purpose of imposition of tax. 30. Whether the husk of Soyabean was covered by the notification dated 7th April 1967 issued by the Madhya Pradesh Government under which sales of husk of all grains, cereals, pulses and rice was exempted, was the question that arose for consideration in General Foods Private Ltd. v. Commissioner of Sales Tax, Bhopal (supra). As the expression cereal, which connotes any grain used for food, has not been defined in the Madhya Pradesh Act and as Soyabean is undoubtedly used as food article, the Madhya Pradesh High Court ruled that husk of Soyabean is covered by the exemption notification. 31. The question for consideration in Kamat and Co. v. State of Karnataka and another (supra), was whether exemption granted from payment of Central Sales tax to a Co-operative Society in Mangalore and denying the same benefit to other registered dealers in the trade was violative of Article 14 of the Constitution ? After examining the factual position and recording a finding that such an exemption is not in the public interest since it entailed loss of revenue, the Karnataka High Court struck down the same on the ground that it suffered from the vice of discrimination. After examining the factual position and recording a finding that such an exemption is not in the public interest since it entailed loss of revenue, the Karnataka High Court struck down the same on the ground that it suffered from the vice of discrimination. We may also incidently mention that during the pendency of the writ petition in the Karnataka High Court, the impugned notification was superseded by another one under which the benefit was granted to the dealers as well as Co-operative Societies, but nonetheless the Court went into the question and quashed the superseded notification. The ratio in each of these precedents cited for the petitioners turned upon its own facts. 32. The second ground urged for the petitioners that since the cotton and cloth components of quilt can be separated there being no manufacturing process involved, cloth being a tax-free item and cotton being liable to tax at the rate of 4 per cent as declared goods under Section 15 of the Central Sales Tax Act, subjecting quilt at 8 per cent is impermissible in law, in our considered view, does not merit acceptance, it is uncontroversial that cloth is tax-free item and cotton is liable to tax at the rate of 4 per cent. The question is : Was quilt sold either as cotton or as cloth ? The answer is an emphatic No. Quilt is not sold either as doth or as cotton, but it is sold only as quilt, a winter garment. 33. A three-Judge Bench of the Supreme Court in State of Punjab and others etc. v. Chandu Lal Kishori Lal, etc., AIR 1969 SC 1073 upheld the plea of the taxing authority that cotton and cotton seeds are two distinct commercial goods and on that view rejected the argument advanced for the assessee that when purchase tax was paid on the purchase of unginned cotton, there was no liability to pay tax on the sales of cotton seeds since cotton as declared goods, already suffered as at the purchase point. The Supreme Court observed very realistically: "It is true that cotton in its unginned state contains cotton-seeds. But it is by a manufacturing process that the cotton and the seed are separated and it is not correct to say that the seeds so separated is cotton itself or part of the cotton. The Supreme Court observed very realistically: "It is true that cotton in its unginned state contains cotton-seeds. But it is by a manufacturing process that the cotton and the seed are separated and it is not correct to say that the seeds so separated is cotton itself or part of the cotton. They are two distinct commercial goods though before the manufacturing process the seeds might have been a part of the cotton itself. There is hence no warrant for the contention that cotton-seed is not different from cotton." 34. Another three-Judge Bench of the Supreme Court in Mis. Bahu Ram Jag-dish Kumar and co. v. State of Punjab and others, AIR 1979 SC 1475, interpreting the earlier precedent in Ganesh Trading Co., Karnal v. State of Haryana, AIR 1974 SC 1362, ruled that paddy and rice are different taxable commodities and they are not one and the same even though rice was produced out of paddy, the latter after dehusking would lose its identity as paddy. 35. Examined in the light of these two rulings what emerges is that the article quilt which the petitioners are selling is a distinct and separate taxable item different from cotton and cloth. When cotton and cloth were utilised in the manufacture of quilt, the former lost their identity and the distinct product that emerged, namely, quilt could be made a separate taxable item. The fact situation is different in Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Er-nakulam v. P.I.O. Food Packers, 1980(46) STC 63, in which it was ruled that although a degree of processing is involved in preparing pineapple slices from the original fruit, the pineapple slices contained in sealed cans continued to possess their original identity notwithstanding the removal of inedible portions, the slicing and thereafter canning it on adding sugar to preserve them. 36. After the manufacturing process was completed and when quilt emerged as a distinct article, it would be totally unrealistic to say that quilt retained the original identity of cotton and cloth, its two components. The manufacturing process had resulted in the loss of original identity of the cotton and cloth, off which quilt is made up. 37. 36. After the manufacturing process was completed and when quilt emerged as a distinct article, it would be totally unrealistic to say that quilt retained the original identity of cotton and cloth, its two components. The manufacturing process had resulted in the loss of original identity of the cotton and cloth, off which quilt is made up. 37. In judging the constitutionality of tax law, the Court should not go by any assumption as regards the existence of any inflexible or iron rule of equality and any rhetoric of non-discrimination should not be allowed to out weight a legitimate State purpose. 38. For the above reasons, sustaining the constitutionality of the impugned notification, we dismiss the writ petition. There will be no order as to costs. Writ Petition dismissed.