Broad meaning of "parenteral" extends exemption to ophthalmic eye drops absorbed through mucous membrane.

Exemption notifications using the term "parenteral" were interpreted broadly to cover medicines not confined to injections but also locally or topically applied preparations that bypass the alimentary canal and enter the bloodstream through mucous membrane or skin. On that construction, ophthalmic eye drops containing chloramphenicol were treated as eligible for exemption because they are applied to the eye and absorbed through the mucous membrane. The disallowance of exemption was therefore set aside in favour of the assessee.

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Issues: Whether ophthalmic eye drops containing chloramphenicol and used for external application qualified for exemption as a parenteral medicine under the relevant exemption notification.

Analysis: The applicable notification exempted patent and proprietary medicines containing chloramphenicol for oral and parenteral use. The broader legal meaning of "parenteral" was adopted, under which the term is not confined to injections alone but extends to medicines applied locally or topically that bypass the alimentary canal and enter the bloodstream through mucous membrane or skin. Eye drops meant for application to the eye fall within that wider understanding when the medicinal substance is absorbed through the eye's mucous membrane.

Conclusion: The eye drops were held to be eligible for exemption under the notification, and the disallowance of exemption was set aside in favour of the assessee.

Ratio Decidendi: For exemption notifications using the expression "parenteral", the term must be given its broader meaning so as to include locally or topically applied medicines that bypass the alimentary canal and enter the bloodstream through mucous membrane or skin.

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