Ordinary meaning of exemption terms: hospital stainless steel utensils qualified for concessional duty under the notification.

Stainless steel hospital utensils were treated as falling within the unqualified expression "stainless steel utensils" in the exemption notification, because the term "utensils" was not restricted by any statutory definition and had to be given its ordinary commercial meaning. The goods were admittedly made of stainless steel, and their use in a hospital setting did not exclude them from the notification. The ISI description of the articles as hospital utensils also supported the classification. On that basis, the articles qualified for concessional duty under Notification No. 53/84-C.E.

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Issues: Whether hospital stainless steel utensils are eligible for concessional duty under Notification No. 53/84-C.E. dated 1-3-1984.

Analysis: The notification granted exemption to stainless steel utensils without defining the term "utensils". The goods were admittedly made of stainless steel, and the expression "utensil" was held not to be confined to household or kitchen articles. The ordinary meaning of the word, the absence of a restrictive statutory definition, and the ISI description of the goods as hospital utensils supported classification as utensils eligible for the notification benefit.

Conclusion: Hospital stainless steel utensils were held to fall within the expression "stainless steel utensils" in the notification and were entitled to the concessional rate of duty.

Ratio Decidendi: Where an exemption notification uses an unqualified commercial term, it must be given its natural and ordinary meaning, and goods answering that description cannot be excluded merely because they are used in a specialised setting.

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