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Interpretation of the expression "exclusively used as a private residential premise" under the Bombay Electricity Duty Act. Analysis: The case involved a dispute regarding the categorization of guest houses maintained by commercial undertakings for their employees in Bombay under the Bombay Electricity Duty Act. The Municipal Corporation categorized the premises under Category 'C' for billing purposes, while the respondents contended that the premises should fall under Category 'R'. The Single Judge upheld the categorization under Category 'C', emphasizing that Category 'R' is restricted to premises used as private residences for permanent or long-term occupants. The Division Bench, however, reversed the decision, stating that since the guest houses were not operated for profit and exclusively used by the company's employees, they should be classified under Category 'R'. The Supreme Court analyzed the expression "exclusively used as a private residential premise" and concluded that the guest houses maintained by commercial undertakings cannot be considered as exclusively used for residential purposes. The Court emphasized that the ordinary meaning of the words should be upheld, and the guest houses, being part of a commercial venture, do not qualify as private residential premises. Therefore, the appeals were allowed, setting aside the Division Bench's judgment and dismissing the writ petitions filed by the respondents. In interpreting the expression "exclusively used as a private residential premise," the Supreme Court emphasized the cardinal principle of statutory construction to give the words their natural meaning. The Court analyzed the relevant provisions of the Bombay Electricity Duty Act, which provided different tariffs for premises used for residential and business purposes. Under the applicable tariff, Category 'R' applied to premises exclusively used as private residential premises, while Category 'C' applied to other premises. The Court held that the guest houses maintained by commercial undertakings for their employees did not meet the criteria of being exclusively used as private residential premises. The Court rejected the Division Bench's reliance on the absence of profit motive and the distinction between private and public use, stating that such factors were irrelevant in interpreting the expression in question. Ultimately, the Court concluded that the guest houses could not be categorized under Category 'R' and upheld the categorization under Category 'C', allowing the appeals and dismissing the writ petitions. The Supreme Court's decision clarified the interpretation of the expression "exclusively used as a private residential premise" under the Bombay Electricity Duty Act. The Court's analysis focused on the natural meaning of the words and the context in which they were used in the statute. By emphasizing that the guest houses maintained by commercial undertakings were not intended for exclusive residential use, the Court rejected the Division Bench's interpretation and upheld the categorization under Category 'C'. The decision provides clarity on the application of different tariff categories under the Act and sets a precedent for similar cases involving the classification of premises for electricity duty purposes.
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