Common parlance interpretation of "footwear" includes sports shoes where no separate classification is made.

The expression "footwear" in the 1 October 1965 notification was construed in its ordinary and popular sense, not a technical or restricted sense. On that approach, it covered the entire class of protective wearing apparel for the feet, including sports shoes as one variety within that class. The absence of any separate classification for sports shoes or different types of shoes meant their use for sport did not exclude them from the generic entry. Sports shoes were therefore included within "footwear" and fell to be taxed under that entry.

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Issues: Whether sports shoes are included in the entry "footwear" in the notification dated 1st October, 1965.

Analysis: The expression "footwear" was construed in its ordinary and popular sense, as understood in common parlance, and not in a technical or restricted sense. The term was treated as a generic one covering the whole class of protective wearing apparel for the feet, and sports shoes were held to be only one variety within that class. Since the legislature had made no separate classification for sports shoes or for different varieties of shoes, the fact that such shoes are used for sports did not take them outside the ordinary meaning of footwear.

Conclusion: Sports shoes are included in "footwear" and are taxable under that entry.

Ratio Decidendi: A generic fiscal entry must be construed in its common parlance sense and includes all varieties falling within its ordinary meaning unless the statute or notification makes a separate distinction.

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