Popular meaning of food exemptions: bread includes Indian varieties, while cooked rice preparations fall outside rice exemption.

Exempting entries for foodstuffs in a sales tax statute are construed in the popular Indian sense. "Bread" was held to include double roti, shirmal and tanure-ki-roti, because the term covers ordinary Indian varieties of bread and not a narrow European culinary meaning. By contrast, "all forms of rice" was held to refer to varieties or kinds of rice, such as broken rice or rice flour, and not cooked rice or rice-based preparations like biriyani and polao. The later amendment expressly listing certain breads was treated as confirmation of the broader meaning of "bread."

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Issues: Whether double roti, shirmal and tanure-ki-roti fall within the exemption for "bread" in item 3 of Schedule I of the Hyderabad General Sales Tax Act, 1950; and whether cooked rice and rice preparations are covered by the exemption for "all forms of rice" in item 1 of Schedule I of that Act.

Issue: Whether double roti, shirmal and tanure-ki-roti fall within the exemption for "bread" in item 3 of Schedule I of the Hyderabad General Sales Tax Act, 1950.

Analysis: The expression "bread" was construed in the sense in which it is understood in India and not by a narrow European culinary meaning. The exempting entry was read as covering all kinds of bread consumed in the country, prepared in different ways or known by different names. The later amended schedule, which specifically included double roti, chapathi, kulcha and shirmal under "bread," confirmed that the legislature intended a broad and inclusive meaning.

Conclusion: The articles double roti, shirmal and tanure-ki-roti are included in "bread" and are exempt from sales tax.

Issue: Whether cooked rice and rice preparations are covered by the exemption for "all forms of rice" in item 1 of Schedule I of the Hyderabad General Sales Tax Act, 1950.

Analysis: The words "all forms of rice" were held to denote varieties or kinds of rice, such as broken rice or rice flour, and not preparations made from rice after cooking or processing. Preparations like cooked rice, biriyani and polao were therefore outside the scope of the exemption.

Conclusion: Cooked rice and rice preparations are not exempt under item 1.

Final Conclusion: Relief was granted only to the extent that the exemption for bread covered the specified bread items, while the claim based on rice preparations failed.

Ratio Decidendi: Exempting entries for foodstuffs in a sales tax statute must be construed in the popular Indian sense, and words like "bread" or "all forms of rice" cover the ordinary kinds or varieties of the article, not distinct cooked preparations made from it.

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