Charitable purpose exemption under municipal tax law can survive student fees and does not require all three statutory objects.

The exemption under section 115(4)(a) of the Delhi Municipal Corporation Act depends on whether the society falls within the inclusive meaning of "charitable purpose", which covers relief of the poor, education, or medical relief; all three elements need not coexist. Charging fees from students does not by itself defeat exemption, because the provision contemplates support by voluntary contributions and permits application of income to the society's objects. The High Court erred in treating medical relief as mandatory and in failing to examine the remaining factual matters relevant to the claim. The exemption issue was decided in favour of the petitioner and the matter was remitted for fresh consideration on the outstanding facts.

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Issues: Whether exemption from general tax under section 115(4)(a) of the Delhi Municipal Corporation Act, 1957 is available to a society running a school on the ground that its activity amounts to a charitable purpose, and whether the charging of fees from students necessarily defeats the claim to exemption.

Analysis: The expression "charitable purpose" in the Explanation to section 115(4)(a) is inclusive and not exhaustive. The statutory test is satisfied if the society exists for relief of the poor, education, or medical relief; it is not necessary that all the three elements must coexist. A fee being charged from students does not by itself negative the claim, because the proviso contemplates support of the society wholly or in part by voluntary contributions and permits application of income towards its objects. The High Court had proceeded on an erroneous understanding that medical relief was also required and had not examined the remaining factual aspects bearing on the claim.

Conclusion: The exemption issue was answered in favour of the petitioner, and the High Court's approach was held to be erroneous. The matter was remitted to the High Court for fresh decision on the remaining factual questions.

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