Inclusive exemption wording can cover khukris as arms when the general term is read in its ordinary popular sense.

An exemption notification using the phrase "all arms including rifles, revolvers, pistols and ammunition" was construed as inclusive, so the listed items were illustrative rather than exhaustive. The general term "arm" was given its ordinary popular meaning as a weapon used for offence or defence, which encompassed a khukri as a cutting or stabbing weapon akin to a sword. The later amendment excluding khukris from the category of arms was treated as supporting the view that khukris were already covered before the amendment. On that basis, khukris fell within the notification dated 1 June 1963.

---

---

Issues: Whether khukri is covered by Notification No. ST-1738/X-1012-1963 dated 1st June, 1963 as an "arm".

Analysis: The notification used the expression "all arms including rifles, revolvers, pistols and ammunition for the same", showing that the listed articles were illustrative and not exhaustive. The word "arm" was treated in its popular sense, and its ordinary meaning was taken to include weapons used for offence or defence. On that approach, a khukri, being a weapon used as a cutting or stabbing instrument like a sword, fell within the ordinary meaning of "arm". The later amendment excluding khukris from the category of arms was treated as supporting the view that khukris had earlier been included.

Conclusion: Khukris are covered by the notification dated 1st June, 1963, and the reference was answered in favour of the Revenue.

Ratio Decidendi: Where an exemption entry uses an inclusive expression, the specified items are illustrative, and the ordinary popular meaning of the general term governs unless the context shows a narrower sense.

---