Purposive interpretation of cinema subsidy rules extends tax-refund benefit to the operating licensee, not just the owner.

The term "swami" in the 1982 subsidy rules is construed purposively to include not only the actual owner of a cinema hall or multiplex, but also the occupier or licensee who operates the cinema, holds the licence, bears contractual obligations, and pays entertainment tax. The subsidy scheme, designed to refund entertainment tax and encourage cinema operations, must be read with the connected cinema and entertainment-tax statutes. Because the tax law uses a broad concept of "proprietor" and the cinema rules distinguish ownership from licence-holding, a narrow ownership-only reading would defeat the scheme's object.

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Issues: Whether the term "swami" in the 1982 subsidy rules includes only the actual owner of a cinema hall or multiplex, or also the person who runs the cinema as licensee and pays entertainment tax, so as to qualify for subsidy by refund of tax.

Analysis: The subsidy scheme under the 1982 Rules was designed to encourage establishment and operation of cinema halls and multiplexes through refund of entertainment tax. The term "swami" was not defined exhaustively in the subsidy rules and had to be read in the setting of the connected cinema and entertainment-tax statutes. The entertainment-tax enactment used a broad concept of "proprietor", covering the person responsible for or in charge of the management, while the cinema regulation rules recognised a distinction between ownership and the holder of the cinema licence. On that basis, the person who actually operates the cinema, holds the licence, bears the contractual obligations, and regularly pays entertainment tax answers the description of the person for whose benefit the subsidy scheme was framed.

Conclusion: The word "swami" in the 1982 Rules includes not only the actual owner but also the occupier or licensee who runs the cinema hall or multiplex and fulfils the statutory and contractual obligations.

Ratio Decidendi: A subsidy provision intended to reimburse entertainment tax must be construed purposively so that the benefit reaches the person actually liable to run the cinema and pay the tax, and not be defeated by a narrow ownership-based interpretation.

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