Charitable hospital property tax exemption depends on actual predominantly free medical relief, not just trust objects or limited free treatment.

Property tax exemption for a charitable hospital under Section 101(e) of the Chennai City Municipal Corporation Act, 1919 depends on strict proof that the institution is in fact run predominantly for charitable medical relief. Its trust objects or some free treatment are not enough; the actual mode of functioning, including whether it mainly serves poor, needy and deserving patients, is decisive. Substantial fee-based treatment, competitive ward rates and only limited free care indicate that the hospital does not satisfy the statutory test. On the stated facts, the claim for exemption failed.

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Issues: Whether the petitioner hospital was entitled to exemption from property tax under Section 101(e) of the Chennai City Municipal Corporation Act, 1919 as a charitable hospital.

Analysis: Exemption from property tax is a statutory concession and must be proved strictly by the claimant. A charitable hospital is identifiable not merely by its trust deed or by some free treatment, but by the manner in which it is actually run and whether it predominantly serves poor, needy and deserving patients. Collecting substantial charges from a large section of patients, charging competitive ward rates and showing only limited free treatment were treated as indicators that the institution was not functioning predominantly as a charitable hospital. The fact that the petitioner's object mentioned free or concessional services did not by itself establish entitlement, and the evidence was held insufficient to show that the hospital was mainly maintained for charitable medical relief.

Conclusion: The petitioner was not entitled to exemption under Section 101(e) of the Chennai City Municipal Corporation Act, 1919 and the claim failed.

Ratio Decidendi: For property tax exemption as a charitable hospital, the institution must be shown on facts to predominantly provide free or genuinely concessional medical relief to the poor and needy; limited free treatment coupled with substantial fee-based services does not satisfy the statutory test.

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