Road roller treated as a motor vehicle for taxation where the statute expressly includes road-use vehicles.

A road roller falls within the statutory definition of a motor vehicle because it is mechanically propelled and adapted for use on roads. The Motor Vehicles Act expressly includes a road roller within the definition of a light motor vehicle, and the taxing power under Entry 57 of List II extends to vehicles suitable for road use. Its use for road repair, rather than for carrying passengers or goods, does not exclude it from taxation. The challenge to the levy therefore failed, and the road roller was held liable to tax under the Andhra Pradesh motor vehicle taxation regime.

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Issues: Whether a road roller is a motor vehicle within the meaning of the Motor Vehicles Act, 1988 and is liable to be taxed under the Andhra Pradesh motor vehicle taxation regime.

Analysis: The power to levy tax on vehicles flows from Entry 57 of List II of Schedule VII of the Constitution of India and extends to vehicles suitable for use on roads. Section 2(28) of the Motor Vehicles Act, 1988 defines a motor vehicle as a mechanically propelled vehicle adapted for use upon roads, and Section 2(21) expressly includes a road roller within the definition of a light motor vehicle. A road roller is designed for use on roads and is not a vehicle confined to off-road use. The statutory definition is clear and cannot be displaced by a narrower functional understanding that would limit a vehicle to the carriage of persons or goods.

Conclusion: A road roller is a motor vehicle within the meaning of the Act and is liable to tax; the challenge to levy of tax failed.

Ratio Decidendi: Where a statute expressly includes a vehicle within the definition of motor vehicle and the vehicle is mechanically propelled and adapted for use on roads, it cannot be excluded from taxation merely because it is used for road repair and not for carrying passengers or goods.

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