Ejusdem generis limits entry tax on packing materials; cotton cloth bags were held outside the taxing entry.

Cotton cloth bags used for packing hybrid seeds were held not to fall within Entry 16-A(v) of the Karnataka Tax on Entry of Goods Act, 1979. Applying ejusdem generis, the court read the words "namely" and "and the like" in context and held that the entry was confined to the enumerated jute-based packing materials such as gunny bags, bardan and hessian cloth. Cotton cloth bags were not goods of the same genus as those specified items, so they were not exigible to entry tax under that entry and the levy was set aside.

---

---

Issues: Whether cotton cloth bags used for packing hybrid seeds were covered by Entry 16-A(v) of the Schedule to the Karnataka Tax on Entry of Goods Act, 1979 and exigible to entry tax.

Analysis: Entry 16-A grouped packing materials by the material from which they were made, and clause (v) dealt with jute-based packing materials such as gunny bags, bardan, hessian cloth and items of the same class. The words "namely" and "and the like" had to be read in context and on the principle of ejusdem generis. The surrounding structure of the entry showed that the Legislature intended to tax only the enumerated classes of packing materials, and not every article loosely described as packing material. Cotton cloth bags were not goods of the same genus as the jute-based items specified in clause (v).

Conclusion: Cotton cloth bags were not covered by Entry 16-A(v) and were not liable to entry tax under that entry.

Final Conclusion: The levy on cotton cloth bags was set aside, and the petitions succeeded.

Ratio Decidendi: Where a taxing entry classifies goods by specified material and uses general words at the end of the class, those words extend only to items of the same genus and do not enlarge the entry beyond the enumerated class.

---