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Issues: Whether the royalty on bricks imposed under the Patiala State Robkar was repealed or rendered invalid by the extension of the Central Excises and Salt Act, 1944 through the Indian Finance Act, 1950, and whether the Robkar was a law corresponding to that Central enactment.
Analysis: Section 13(2) of the Indian Finance Act, 1950 repealed only a law in force in a State that corresponded to an Act extended under Section 11. The Central Excises and Salt Act, 1944 was held to be a limited charging statute confined to excisable goods specified in its Schedule, and not a code that displaced all other local levies by implication. The royalty under the Robkar, though argued to resemble excise, was not shown to be a law corresponding to the Central enactment. As a result, the levy was not hit by the repeal provision, and the prior levy was also protected by the constitutional saving for pre-Constitution State levies.
Conclusion: The Robkar remained effective and the challenge to the brick royalty failed.