Noscitur a sociis limits tax notification entries: plastic and glass bangles fell outside the listed goods.

Plastic bangles and glass bangles were held not to fall within the notification entries for glass sheets and articles made of glass, or plastic sheets and articles made from plastic, under the Karnataka Tax on Entry of Goods Act, 1979. Applying noscitur a sociis, the wider expressions were confined by the specific associated words, so the entries could not be stretched to cover bangles, which were not articles of the same class as sheets. On that construction, the circular and levy were quashed.

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Issues: Whether plastic bangles and glass bangles fall within Serial Nos. 30 and 54 of the notification list under the Karnataka Tax on Entry of Goods Act, 1979.

Analysis: The entries referred to glass sheets and articles made of glass, and plastic sheets and articles made from plastic. The expressions had to be read in their contextual setting, and the associated words limited the wider phrases. Applying noscitur a sociis, the general words were not to be extended beyond the class indicated by the specific words. Bangles were not comparable to glass sheets or plastic sheets, and therefore could not be treated as covered by the entries.

Conclusion: Plastic bangles and glass bangles were not covered by the entries, and the circular and levy based on that construction were quashed in favour of the petitioners.

Ratio Decidendi: Where tariff or notification entries use specific words alongside general words, the general words must be confined by the context and associated expressions, and cannot be extended to articles not genuinely of the same class.

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