Purposive interpretation of mine exemption extends to adjacent workshop serving exclusive mining operations.

Parts and accessories manufactured in a workshop adjacent to a mine were treated as eligible for exemption when they were used exclusively for mining machines of the same company and formed part of the mining operations. The interpretation of "mine" under the Mines Act, 1952 was read with a purposive construction of the exemption notification, and the term "precincts" was given a wider meaning than a strict literal approach. On that basis, a workshop in the environs of a mine, under the same management and serving mine-related purposes, could fall within the exemption, and the duty demand was not sustainable.

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Issues: Whether parts and accessories manufactured in a workshop adjacent to a mine, and used solely for mining machines of the same company engaged in coal mining, were entitled to exemption under the relevant notification notwithstanding that the workshop was not located strictly within the mine precincts.

Analysis: The workshop was not within the mining area but was adjacent to it, belonged to the same company, and was used exclusively for mining operations. The exemption notification had to be read with the meaning of "mine" in Section 2(j) of the Mines Act, 1952, which includes workshops and stores situated within the precincts of a mine and under the same management and used solely for mine-related purposes. The expression "precincts" was held to be of wider import, and the purposive construction was preferred over a narrow literal reading, because the object of the notification was to encourage the mining industry. The Court followed the Supreme Court decision holding that a workshop in the environs of a mine, serving its mining operations and under the same management, can fall within the exemption.

Conclusion: The exemption was admissible and the demand of duty could not be sustained; the impugned order was set aside and the appeal was allowed.

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