Printed receipt books as works contract, not sale, where transfer of paper and ink was only incidental to printing work.

Supply of printed receipt books was treated as a composite printing transaction rather than a sale of goods, because the paper and ink used were the printer's property only until the printing work was completed and any transfer of those materials was merely incidental to the main obligation to execute the printing job. On the facts found, the dominant nature of the contract was work and labour, not a transfer of chattel as such. The transaction was therefore characterised as a works contract and not a sale.

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Issues: Whether the supply of printed receipt books to the Electricity Board was a sale or a works contract.

Analysis: The supply arose from a printing job in which the paper and ink used in the process were initially the printer's property, but the transfer of those materials after printing was only incidental to the main obligation to execute the printing work. The transaction was of a composite nature and, on the facts found, did not constitute a sale of goods.

Conclusion: The supply was held to be a works contract and not a sale, and the appeal failed.

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