Restrictive meaning of "namely" in exemption notifications confines cattle-feed relief to expressly listed items.

In an exemption notification using the phrase "cattle feed, namely," the word "namely" is treated as restrictive, confining the exemption to the items specifically listed after it. The drafting choices "namely," "for example," "that is to say," and "such as" are not interchangeable, and the presence of express exclusions does not expand the notification's scope. On that construction, only the enumerated cattle-feed items fall within the exemption, and tapioca thippi dust and the mixture of molasses with tapioca thippi dust are outside it.

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Issues: Whether the expression "cattle feed" in the exemption notification issued under section 17(1) of the Tamil Nadu General Sales Tax Act, 1959, read with the word "namely", is restrictive so as to confine exemption only to the items specifically enumerated in the notification, or whether it is illustrative so as to include tapioca thippi dust and the mixture of molasses with tapioca thippi dust.

Analysis: The notification used the expression "cattle feed, namely, hay or straw or rice bran or wheat bran or husk and dust of pulses and grams". The Court treated the word "namely" as a term of restriction, indicating that the general description is confined to the items expressly listed after it. The different expressions used in the statute and in other notifications, such as "namely", "for example", "that is to say", and "such as", were treated as deliberate and not interchangeable. On that basis, the Court held that the exemption could not be expanded to all goods that might broadly answer the description of cattle feed. The exclusion of certain items in the notification did not alter this construction and was treated as a precautionary exclusion.

Conclusion: The notification is restrictive, and tapioca thippi dust and the mixture of molasses with tapioca thippi dust are not covered by it.

Ratio Decidendi: In an exemption notification, the word "namely" is restrictive and confines the general expression to the items specifically enumerated after it.

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