Common parlance test for toilet requisites: hairpins and hairclips fall within the taxable entry as grooming articles.

Hairpins and hairclips were construed in common parlance rather than by a narrow technical meaning of "cosmetics and toilet requisites" under Notification No. S.T. 905/X dated 31 March 1956. The court reasoned that these articles are not cosmetic preparations used to beautify, cleanse, colour, condition or protect the body, but appliances for holding and arranging hair. It rejected the narrower view that only consumable cosmetic products were covered and held that "toilet requisites" extends to articles used in dressing, grooming and arranging the person. On that basis, hairpins and hairclips were treated as taxable toilet requisites in favour of the Revenue.

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Issues: Whether hairpins and hairclips are "cosmetics and toilet requisites" within item No. 6 of Notification No. S.T. 905/X dated 31st March, 1956, and are therefore taxable at the prescribed rate.

Analysis: The expression "cosmetics and toilet requisites" was not defined in the statute and had to be understood in common parlance. Hairpins and hairclips are not preparations used to beautify the body or to cleanse, colour, condition or protect hair or skin; they are appliances used to hold and arrange hair. The broader commercial and popular meaning of "toilet requisites" includes articles used in dressing, grooming and arranging the person, and the view that the entry must be confined only to consumable cosmetic preparations was rejected. The reasoning in the earlier Division Bench decision was found too narrow, and the articles were held to fall within toilet requisites rather than cosmetics.

Conclusion: Hairpins and hairclips are toilet requisites under item No. 6 of Notification No. S.T. 905/X dated 31st March, 1956 and are taxable accordingly, in favour of the Revenue.

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