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Issues: Whether a video parlour exhibiting pre-recorded cassettes through VCR/VCP falls within the definition of "cinematograph" under the relevant cinema statutes, requiring a licence for exhibition.
Analysis: The definition of "cinematograph" in the statutes is inclusive and extends to any apparatus for the representation of moving pictures or series of pictures. Such a definition is not confined to apparatus known at the time of enactment, but must receive a construction that accommodates later scientific and technological developments. VCR/VCP perform the same function as traditional exhibition media for moving pictures, and nothing in the statutes excludes their application to such equipment.
Conclusion: The expression "cinematograph" includes VCR/VCP used for exhibition of films, and a licence is required under the relevant statutory regime.