Common parlance governs sales tax classification of salt petre, keeping it outside "chemicals of all kinds"

Salt petre or kalmi sora was held not to fall within "chemicals of all kinds" in the sales tax notification because the term must be construed in its ordinary commercial sense, not by scientific or technical classification. On that commercial-parlance approach, salt petre was not ordinarily used in manufacturing or processing and was commonly treated as a food article, so it did not answer the description of a chemical under the notification. The commodity was therefore taxable only as an unclassified item.

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Issues: Whether salt petre fell within the expression "chemicals of all kinds" in the sales tax notification and was therefore taxable as a chemical rather than as an unclassified item.

Analysis: The expression "chemical" in the notification was to be understood not in a scientific or technical sense but in the sense in which it is ordinarily understood in the commercial world. On that approach, salt petre or kalmi sora, which is not ordinarily used in manufacturing or processing activity and is commonly treated as a food article, does not answer the description of a chemical under the notification. Earlier authority had already treated salt petre as outside the scope of the term as used in the notification.

Conclusion: Salt petre was not covered by the notification as a chemical and was taxable only as an unclassified item.

Ratio Decidendi: A commodity described in a sales tax notification must be construed according to its common parlance and commercial meaning, and not by its scientific character.

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