Land revenue surcharge upheld as a valid State levy and not discriminatory under Article 14.

A surcharge imposed as an enhancement of existing land revenue was held to fall within the State's legislative power over land revenue, rather than constituting a separate tax. The Court found that the extent of the increase did not alter the nature of the levy, and the temporary character of the measure, in the context of continuing settlement and resurvey, supported legislative competence. On Article 14, the Court applied the settled test of intelligible differentia and rational relation to the object and held that differential incidence arising from post-reorganisation revenue arrangements was not hostile discrimination. The constitutional challenge failed and the surcharge legislation was upheld.

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Issues: (i) Whether the Mysore Legislature was competent to enact the surcharge on land revenue as an impost falling within the legislative field of land revenue. (ii) Whether the levy was discriminatory and violative of Article 14 of the Constitution.

Issue (i): Whether the Mysore Legislature was competent to enact the surcharge on land revenue as an impost falling within the legislative field of land revenue.

Analysis: The surcharge was treated as an enhancement of land revenue and not as a separate tax on land revenue. The Court held that a surcharge on existing land revenue squarely fell within the State's power over land revenue and that the nature of the levy was not altered by the extent of the increase. The temporary character of the measure and the context of continuing settlement and resurvey in the State supported the legislative choice.

Conclusion: The levy was within legislative competence and the challenge on this ground failed.

Issue (ii): Whether the levy was discriminatory and violative of Article 14 of the Constitution.

Analysis: The Court applied the settled test of permissible classification, namely intelligible differentia and rational relation to the object sought to be achieved. It held that the differential incidence of surcharge arose from the reorganisation of the State, the continuance of pre-existing revenue arrangements, and the temporary nature of the measure pending resettlement and survey. In these circumstances, the variation in burden did not amount to hostile discrimination.

Conclusion: The levy did not infringe Article 14 and the constitutional challenge failed.

Final Conclusion: The surcharge legislation was upheld as a valid exercise of State power, and the constitutional objections were rejected.

Ratio Decidendi: A surcharge imposed as an enhancement of existing land revenue may validly fall within the State's legislative power over land revenue, and differential treatment resulting from a temporary fiscal measure during post-reorganisation settlement does not violate Article 14 unless it lacks a rational basis.

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