Summarize the following court judgment. Civil Appeal Nos. 2120 & 2125 of 1970. From the Judgment and order dated the 17th April	 1970 of the Delhi High Court in Civil Writ Petitions Nos. 133 & 134 of 1968 Kapil Sibal	 Rameshwar Dial	 Adarsh Dial and section Mittar for the Appellants. K. B. Rohtagi for the Respondents. The following Judgment of the Court was delivered by CHINNAPPA REDDY	 J. BY a notification dated 31.1.68	 the Delhi Municipal Corporation purported to enhance the fee for slaughtering animals in its slaughter houses from Re. 00.25p to Rs. 2.00 for each animal	 in the case of sheep	 goats and pigs	 and li from Re. 1.00 to Rs. 8.00 for each animal	 in the case of buffaloes. The notification was quashed by the High Court of Delhi on the ground that the Corporation was really proposing to levy a tax under the guise of enhancing the fee. The original rates were fixed in March 1953 and the revised rates were to take effect from February 1	 1968. Some butchers of the city questioned the revision of rates on the ground that the proposed enhanced fee was wholly disproportionate to the cost of the services and supervision and was in fact not a fee	 but a tax. The High Court accepted the contention of the butchers on what appears to us a superficial view of the facts and principles. Fortunately	 the High Court has certified the case as a fit one for appeal under article 133 (1)(c) of the Constitution and the matter is now before us. 1002 During the pendency of the writ petitions in the High Court	 by virtue of an interim arrangement	 the Municipal Corporation was permitted to collect fee at the rate of Re. 00.50p. per animal in the case of sheep	 goats and pigs and Rs. 2.00 per animal in the case of buffaloes. As a result	 the Municipal Corporation realised a sum of Rs. 4	24	494 by way of fee for slaughtering animals in its slaughter houses. Now	 the budget of the Municipal Corporation under item XIV B showed a sum of Rs. 2	56	000 as the expenditure involved in connection with the slaughter houses. Comparing the amount of actual realisation of fee at the rates permitted by the Court with the amount of expenditure as revealed by the budget and excluding from consideration all expenditure not show in the budget under item XIV B	 the High Court came to the conclusion that even if the original fee was doubled the amount realised would be more than sufficient to meet the expenditure involved and there was	 therefore	 no warrant at all for increasing the fee eight fold. So	 it was said	 the proposed fee was no fee but a tax for which there was no legislative mandate. We shall presently point out the error into which the High Court fell on facts as well as principle. A word on interpretation. Vicissitudes of time and necessitude	 of history contribute to changes of philosophical attitudes	 concepts	 ideas and ideals and	 with them	 the meanings of words and phrases and the language itself. The philosophy and the language of the law are no exceptions. Words and phrases take colour and character from the context and the times and speak differently in different contexts and times. And	 it is worthwhile remembering that word	 and phrases have not only a meaning but also a content	 a living content which breathes	 and so	 expands and contracts. This is particularly so where the words and phrases properly belong to other disciplines. 'Tax ' and 'Fee ' are such words. They properly belong to the world of Public Finance but since the Constitution and the laws are also concerned with Public Finance	 these words have often been adjudicated upon in an effect to discover their content. Commissioner of Hindu Religious Endowments	 Madras vs Shri Lakshmindra Thirtha Swamiyar(1) is considered the locus classicus on the subject of the contradistinction between 'tax ' and fee?. The definition of 'tax ' given by Latham	 C.J. as "a compulsory exaction 1003 of money by public authority for public purposes enforceable by law and not payment for services rendered" was accepted	 by the Court as stating the essential characteristics of a tax. Turning to fees	 it was said "a fee is generally defined to be a charge for a special service rendered to individuals by some governmental agency"	 but it was confessed	 "as there may be various kinds of fee	 it is not possible to formulate a definition that would be applicable to all cases". As regards the distinction between a tax and a fee	 it was noticed that compulsion could not be made the sole or even a material criterion for distinguishing a tax from fee. It was observed that the distinction between a tax and fee lay primarily in the fact that tax was levied as a part of a common burden	 while a fee was a payment for a special benefit or privilege. But it was noticed that the special benefit or advantage might be secondary to the primary motive of regulation in the public interest	 as for instance in the case of registration fees for documents or marriage licences. It was further noticed that Article 110 of the Constitution appeared to indicate two classes of cases where 'fees ' could be imposed: (1) where the government simply granted a permission on privilege to a person to do something which otherwise that person would not be competent to do and extracted from him	 in return	 heavy or moderate fees (ii) where the government did some positive work for the benefit of the person and money was taken as a return for the work done or services rendered	 such money not being merged in the public revenues for the benefit of the general public. It was however made clear that the circumstance that all the collections went to the Consolidated Fund of the State and not to a separate fund may not be conclusive. The Court finally observed that there was really no generic difference between the tax fees though the Constitution had	 for legislative purposes	 made a distinction between a tax and a fee. While there were entries in the legislative lists with regard to various forms of taxes	 there was an entry at the end of each one of the three lists as regards fees which could be levied in respect of any of matters that was included in it. The implication seemed to be that fee had special reference to governmental action undertaken in respect to any of those matters. In HH Sudhandra vs Commissioner for Hindu Religious & Charitable Endowments(1)	 the Court reiterated the principle that a levy in 1004 the nature of a fee did not cease to be of that character merely because there was any element of compulsion or coerciveness present in it	 and aided. "Nor is it a postulate of a fee that it must have direct relation to the actual services rendered by the authority to individual who obtains the benefit of the service. If with a view to provide a specific service	 levy is imposed by law and expenses for maintaining the service are met out of the amounts collected there being a reasonable relation between the levy and the expenses incurred for rendering services	 the levy would be in the nature of a fee and not in the nature of a tax . . but a levy will not be regarded as a tax merely because of the absence of unity in its incidence	 or because of compulsion in the collection thereof	 nor because some of the contributories do not obtain the same degree of service as others may. " In Hingir Rampur Coal Co. Ltd. & Ors. vs The State of Orissa and Ors.(1) the Court while reiterating that there was an element of quid pro quo between the person paying the fee and the authority imposing it	 said: "If specific services are rendered to a specific area or to a specific class of persons or trade or business in any local area	 and as a condition precedent for the said services or in return for them cess is levied against the said area or the said class of persons or trade or business	 the cess is distinguishable from a tax and is described as a fee." Later it was said: "It is true that when the legislature levies a fee for rendering specific services to a specified area or to specified	 class of persons or trade or business	 in the last analysis such services may indirectly form part of services to the public in general. If the special service rendered is distinctly and primarily meant for the benefit of a specified class or area the fact that in ben fitting the specified class or area the State as a whole may 1005 ultimately and indirectly be benefitted would not detract from the character of the levy as a fee. Where	 however	 the specific	 service is indistinguishable from public service	 and in essence is directly a part of it	 different considerations may arise. In such a case	 it is necessary to enquire what is the primary object of the levy and the essential purpose which it is intended to achieve. Its primary object and the essential purpose must be distinguished from its ultimate or incidental results or consequences. That is the true test in determining the character of the levy	 In H.H. Swamiji vs Commissioner, Hindu Religious & Charitable Endowments Department and Ors.,(1) Chandrachud, CJ. speaking for the Constitution Bench, emphasised the necessity as well as the sufficiency of a broad correlationship between the services rendered and the fees charged and discounted the attempts to go into minutiae to discover meticulously whether or not there was mathematical equality. He said, For the purpose of finding whether there is a correlationship between the services rendered to the fee payers and the fees charged to them	 it is necessary to know the cost incurred for organising and rendering the services. But matters involving consideration of such a correlationship are not required to be proved by a mathematical formula. What has to be seen is whether there is a fair correspondence between the fee charged and the cost of services rendered to the fee payers as a class. The further and better particulars asked for by the appellants under VI	 rule 5 of the Civil Procedure Code	 would have driven the Court	 had the particulars been supplied	 to a laborious and fruitless inquiry into minute details of the Commissioner 's departmental budget. A vivisection of the amounts spent by the Commissioner 's establishment at different places for various purposes and the ad hoc allocation by the Court of different amounts to different heads would at best have been speculative. It would have been no more possible for the High Court if the information were before it	 than it would be possible for us if the information were before us. to find out what part of the expenses incurred by the Commissioner 's establishment at various places and what part of the salary of his staff at those places should be allocated to the functions 1006 discharged by the establishment in connection with the services rendered to the appellants. We do not therefore think that any substantial prejudice has been caused to the appellants by reason of the non supply of the information sought by them." In Southern Pharmaceuticals & Chemicals Trichur & Ors. etc. vs State of Kerala & Ors. etc. 	(1) A.P.Sen	 J. speaking for the Court noticed the broadening of the Court 's attitude and observed: "It is now increasingly realised that merely because the collections for the services rendered or grant of a privilege or licence	 are taken to the consolidated fund of the State and are not separately appropriated towards the expenditure for rendering the services is not by itself decisive. That is because the Constitution did not con template it to be an essential element of a fee that it should be credited to a separate fund and not to the consolidated fund. It is also increasingly realised that the element of quid pro quo stricto senso is not always a sine qua non of a fee. It is needle to streess that the element of quid pro quo is not necessarily absent in every tax. . The Traditional Concept of Quid Pro Quo Is Undergoing. A Transformation. " What do we learn from these precedents? We learn that is no generic difference between a tax and a fee	 though broadly a tax is a compulsory exaction as part of a common burden	 without promise of any special advantages to classes of taxpayers whereas a fee is a payment for services rendered	 benefit provided or privilege conferred '. Compulsion is not the hall mark of the distinction between a tax and a fee. That the money collected does not go into a separate fund but goes into the consolidated fund does not also necessarily make a levy a tax. Though a fee must have relation to the services rendered	 or the advantages conferred	 such relation need not be direct . a mere causal relation may be enough. Further	 neither the incidence of the fee nor the service rendered need be uniform. That others besides those paying the fees are also benefited does not detract from the character of the fee. In fact the special benefit or advantage to the payers of the fees may even be secondary as com 1007 pared with the primary motive of regulation in the public interest. Nor is the Court to assume the role of a cost accountant. It is neither necessary nor expedient to weigh too meticulously the cost of the services rendered etc. against the amount of fees collected so as to evenly balance the two. A broad correlationship is all that is necessary. Quid pro quo in the strict sense is not the one and only true index of a fee; nor is it necessarily absent in a tax. What do we have in the present case ? True	 the Municipal Corporation has realised a sum of Rs. 4	24	494 by way of fees at the rate of Re. 00.50p. per animal in the case of sheep	 goats and pigs and Rs. 2.00 per animal in the case of buffaloes	 whereas the budget of the Municipal Corporation showed under item XIV B that an amount of Rs. 2	56	000 was expended in connection with slaughter houses. But as explained in the affidavit of Dr. A. C. Ajwani Deputy Health officer (Public Health) of the Municipal Corporation of Delhi	 the amount of Rs. 2	56	000 covers only those items of expenditure as are reflected in item XIV B of the Municipal Budget. The items of expenditure covered by item XIV B of the municipal budget are evidently those item of expenditure which arc incurred directly and excessively in connection with slaughter houses. In addition there are several other items of expenditure connected with slaughter houses but which are not included in item XIV B. To name a few	 . there is the expenditure involved in the purchase	 maintainance and the use of trucks and other vehicles for the removal of filth and refuse from slaughter houses. These expenses	 though attributable to slaughter houses	 are debited in the municipal budget under other heads such as transport	 conservancy	 petrol and oil etc. There is also the expenditure incurred in connection with the maintainance of supervisory staff like a full time Veterinary officer	 and a Municipal Health officer	 Deputy Health officer	 Zonal Health officer etc.	 a considerable part of those duties are connected with slaughter houses. There is then the cost of depreciation of the buildings and fittings in the slaughter houses. There is also the provision for expansion and improvement of slaughter house facilities. There are several other items of expenditure the whole or part of which is attributable to slaughter houses. Unfortunately	 the High Court refused to look at any of these formidable items of expenditure on the ground that the Corporation could not ask the Court to look at any figures other than the figure mentioned under item XIV B of the municipal budget. Aparently the High Court was under the impression that the fees collected should be shown to be related to 1008 expenditure incurred directly and exclusively in connection with the slaughtering of animals in its slaughter houses and also	 shown as such in the municipal budget. This was a wholly erroneous approach	 in the light of what we have said earlier. We have explained earlier that the expenditure need not be incurred directly nor even primarily in connection with the special benefit or advantage conferred. We have also explained that there need not be any fastidious balancing of the cost of the services rendered with the fees collected. It appears to have been common ground before the High Court that the price of meat had gone up about 10 to 12 times since the rates were original fixed. If so	 one wonders how the Municipal Corporation could be expected to effectively discharge its obligations in connection with the supervision of the slaughtering of animals in the slaughter houses maintained by it by merely raising the rates two fold and three fold. The increase from Re. 00.25p to Rs. 2.00 per animal in the case of small animals and from Re. 1.00 to Rs. 8.00 in the case of large animals appears to us to be wholly justified in the circumstances of the case. The appeal is therefore	 allowed with costs the judgment of the High Court set aside and the Writ Petition filed in the High Court dismissed with costs. S.R. Appeal allowed.

As per the rates fixed in the year 1953 by the Municipal Corporation of Delhi	 the slaughtering fees were 0.25 paise for each animal	 in the case of sheep	 goats and pigs and rupees one for each animal in the case of buffaloes. By a Notification dated 31.1.1968	 the Corporation purported to enhance the slaughtering fee in both the categories eightfold	 with effect from February 1 1968. Some butchers of the city questioned the revision of rates on the ground that the proposed enhanced fee was wholly disproportionate to the cost of the services and supervision and was in fact not a fee	 but a tax. During the pendency of the writ petitions in the High Court	 by virtue of an interim arrangement	 the appellant	 was permitted to collect slaughtering fees at double the rates fixed in 1953 and as a result thereof the Corporation realised a sum of Rs. 4	24	494/ . The budget of the Corporation under item XIV B showed a sum of Rs. 2	56	000 as the expenditure involved in connection with the slaughter houses. Comparing the amount of actual realisation of fee at the rates permitted by the court with the amount of expenditure as revealed by the budget and excluding from consideration all expenditure not shown in the budget from item XIV B	 the High Court came to the conclusion that even if the original fee was doubled the amount realised would be more than sufficient to meet the expenditure involved and	 therefore	 there was no reason at all for increasing the fee eightfold and so the proposed fee was no fee but a tax for which there is no legislative mandate. Hence the appeal by special leave. Allowing the appeal	 the Court ^ HELD: 1;1 The increase of the slaughtering fee from 0.25 P to Rs. 2.00 per animal in the case of small animals and from rupee 1.00 to Rs. 8.00 in the case of large animals was wholly justified	 in the Circumstances of the case. [1008 C D] 1:2 True	 the Municipal Corporation has realised a sum of Rs. 4	24	494 way of fees at the rate of Re. 00.50 per animal in the case of sheep	 goats 1000 and pigs and Rs. 2 per animal in the case of buffaloes	 whereas the budget of the M.C.D. showed under item XIV B that an amount of Rs. 2	56	000 was expended in connection with slaughter houses. The Items of expenditure covered by item XIV B of the Municipal Budget are evidently those items of expenditure which are incurred directly and exclusively in connection with slaughter houses. There are several other items of expenditure the whole or part of which is attributable to slaughter houses like the expenditure involved in the purchase	 maintenance and the use of trucks and other vehicles for the removal of filth from slaughter houses	 conservancy	 petrol oil etc. 	 the expenditure incurred in connection with the maintenance of supervisory staff like a fulltime Veterinary officer	 Municipal Health officer	 Deputy Health officer and Zonal Head officers	 the cost of depreciation of the buildings and fittings in slaughter houses	 expansion and improvement of slaughter houses for utilities etc. but actually debited to other heads of account under the Municipal budget. Apparently	 the High Court was under an erroneous impression that the fees collected should be shown to be related to expenditure incurred directly and exclusively in connection with the slaughtering of animals in its slaughter houses and also	 shown as such in the Municipal budget. [1007 B H	 1008 A B] 2. Vicissitudes of time and necessitudes of history contribute to changes of philosophical attitudes	 concepts	 ideas and ideals and	 with them	 the meanings of words and phrases and the language itself. The philosophy and the language of the law are no exceptions. Words and phrases take colour and character from the context and the times and speak differently in different contexts and times. Words and phrases have not only a meaning but also a content	 a living content	 which breathes	 and so	 expands and contracts. This is particularly so where the words and phrases properly belong to other disciplines. "Tax" and "Pee" are such words. They properly belong to the world of public finance but since the Constitution and the laws are also concerned with Public Finance	 these words have often been adjudicated upon in an effort to discern their content. [1002 D G] 3. From the decided cases beginning from Commissioner of Hindu Religious Endowments	 Madras vs Shri Lakshmindra Thirtha Swamiyar ; till date	 it is clear that: (i) There is no generic difference between a tax and fee	 though broadly a tax is a compulsory exaction as part of a common burden	 without promise of any special advantages to classes of tax payers whereas a fee is a payment for services rendered; benefit provided or privilege conferred; (ii) Compulsion is not the hall mark of the distinction between a tax and fee; (iii) That the money collected does not go into a separate fund but goes into the Consolidated Fund does not also necessarily make a levy tax; (iv) Though a fee must have relation to the services rendered	 or the advantage conferred	 such relation need not be direct; a mere casual relation may be enough; (v) Further neither the incidence of the fee nor the service rendered need be uniform	 (vi) That others besides those paying the fees are also benefited does not detract from the character of the fee; (vii) In fact the special benefit or advantage to the payers of the fees may even be secondary as compared with the primary motive of regulation in the public interest; (viii) Nor is the court to assume the role of a Cost Accountant. It is neither necessary nor expedient to weigh too meticulously the cost	 of the services rendered 1001 etc. against the amount of fees collected so as to evenly balance the two and (ix) A correlationship is all that is necessary. Quid pro quo in the strict sense is not the only true index of a fee; nor is it necessarily absent in a tax. [1006 E H	 1007 A B] Commissioner of H.R. & C.E.	 Madras vs Shri Lakshmindra Thritha Swamiyar	 ; ; H. H. Sudhundra vs Commissioner for Hindu Religious and Charitable Endowments	 [1963] Supp. 2 S.C.R. 302; Hingir Rampur Coal Co. Ltd. and others vs The State of Orissa and others	 [196] 2 S.C.R. 537; H. H. Swamiji vs Commissioner Hindu Religious & Chariiable Endowments Dept. and others	 ; Southern Pharmaceuticals & Chemicals	 Trichur and others etc. vs State of Kerala and others; 	 referred to.