Wide construction of "in connection with manufacture" upheld for cess on limestone used in iron and steel production.

Section 3 of the Limestone and Dolomite Mines Labour Welfare Fund Act, 1972 was construed broadly because the cess is designed to create a labour welfare fund and the phrase "for any purpose in connection with the manufacture of" must be given an effective, wide meaning. A narrow reading would defeat the levy in industries where limestone is not directly used in the final product but is used for activities having a real nexus with manufacture. Limestone used for purposes relatable to the manufacture of iron and steel therefore attracts cess, and the interpretation adopted by the High Court is affirmed.

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Issues: Whether the expression "for any purpose in connection with the manufacture of ... iron, steel..." in Section 3 of the Limestone and Dolomite Mines Labour Welfare Fund Act, 1972 is to be construed narrowly or widely for the purpose of levy of cess on limestone used by the mine owner.

Analysis: The provision levies a cess to create a labour welfare fund, and its language and object require a broad construction. A narrow reading would make the levy ineffective in many covered industries, since limestone may not be directly used in the final manufacture but may still be used for purposes connected with it. The expression "in connection with" is therefore wide enough to cover activities having a real nexus with the manufacture of the specified goods, including iron and steel.

Conclusion: The provision must be construed widely, and limestone used for purposes relatable to and in connection with the manufacture of the specified commodities attracts the cess. The challenge fails and the interpretation adopted by the High Court is affirmed.

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