Summarize the following court judgment. Civil Appeal Nos. 912 to 916 of 1971. Appeals by Special Leave from the Judgment and Order dated the 2nd July 1969 of the Orissa High Court in Special Jurisdiction Cases Nos. 73	 74	 75 and 76 of 1964. V. C. Mahajan and R. N. Sachthey: for Appellants (In CAs. 912 13/71) R. N. Sachthey; for Appellant in CAs. 914 16/71. Gobind Das	 amicus curiae for Respondent. The Judgment of the Court was delivered by GOSWAMI	 J. Five quarters of assessment of sales tax are involved in these five appeals	 by special leave	 the period commencing from January 1	 1959 to March 31	 1960. This judgment will govern all these appeals involving a common question. The Assistant Sales Tax Officer	 Cuttack	 included in the turnover of the respondent the sale price of jeera	 dhania (coriander)	 panmohuri	 methi	 postak and pipall and levied 5 per cent sales tax under the Orissa Sales Tax Act (briefly the State Act). On appeal the Assistant Commissioner of Sales Tax	 Puri	 allowed the claim of the respondent and held that the above items are oil seeds within the meaning of section 14(vi) of the and gave the respondent the benefit of a lower tax of 2 per cent on the sale turnover of those goods instead of 5 per cent under the State Act. On appeal by the State of Orissa to the Sales Tax Tribunal claiming 5 per cent on the sale turnover thereof under the provisions of the 	 the orders of the Assistant Commissioner were affirmed. On application by the State for each of the five quarters	 the Tribunal referred the following two common questions under section 24 of the State Act: "(1) Whether in the facts and circumstances of the case	 the Sales Tax Tribunal is right in holding that jeera	 dhania	 panmohuri	 methi	 postak and pipali are oil seeds within the meaning of section 14 of the Central Act and the tax payable under the State Law in respect of the sale or purchase of these goods inside the State	 cannot exceed 2 per cent of the sale or purchase price thereof. (2) Whether the communication No. 4(8) ST/57 dated 31st January	 1958	 issued by the Government of India which is only an official communication having no statutory sanction behind it can have any legal effect to hold the goods in question as oil seeds as understood in common parlance and whether such an official communication is binding on the State Government. " We are not concerned with 'pipali ' in these appeals. 968 When these appeals came before us for hearing the respondent was not represented. We	 therefore	 requested Mr. Gobind Das to act as amicus curiae in these appeals. Before we may proceed further	 we may immediately turn to section 14(vi) of the (briefly the Central Act): "14. Certain goods to be special importance in inter State trade or commerce. It is hereby declared that the following goods are of special importance in inter State trade or commence: (vi) Oil seeds	 that is to say	 seeds yielding non volatile oils used for human consumption	 or in industry	 or in the manufacture of varnishes	 soaps and the like	 or in lubrication	 and volatile oils used chiefly in medicines	 perfumes	 cosmetics and the like". The above definition is an explanatory one and uses mentioned therein cover a wide range. If the particular items which are assessed under the State Act can be brought under the definition of "oil seeds"	 as given in the above provision	 the assessee will be entitled to a lower levy of sales tax. Mr. Mahajan appearing on behalf of the appellant sumbits that the Court should adopt the meaning given to these items in common parlance and by the people who use the articles. He chiefly relies upon a decision of the Andhra Pradesh High Court in The State of Andhra Pradesh vs Kajjam Ramchandraiah Gari Anantaiah. In that case the High Court was dealing	 inter alia	 with an identical item	 viz.	 dhania (coriander) under item 3 of Schedule IV of the Andhra Pradesh General Sales Tax Act	 1957. Item 3 is identical with item (vi) of section 14 of the Central Act giving the definition of "oil seeds". The Andhra Pradesh High Court relied upon a letter from the Director of the National Chemical Laboratory	 Poona	 dated January 29	 1959	 addressed to the Secretary	 Council of Scientific and Industrial Research	 New Delhi	 as also upon another letter from the Central Food Technological Research Institute	 Mysore	 dated February 18	 1959	 and came to the conclusion that	 amongst other things	 dhania (coriander) did not come "within the definition of oil seeds". The High Court also held that it was not difficult to envisage with the increase in scientific knowledge and technological development that oil could be extracted from any seed which might not be known as an oil seed in common parlance. That Court also observed that there was no evidence to show that any oil was extracted in this country or that the oil extracted from the seeds concerned was used commercially or industrially or could be bought in the market. In this view of the matter the Andhra Pradesh High Court held that dhania and other seeds which came up for consideration were not oil seeds under item 3 of Schedule IV of the Andhra Pradesh Sales Tax Act. It is interesting that on this finding of that Court coriander escaped altogether from assessment. 969 In Commissioner of Sales Tax	 Madhya Pradesh	 Indore	 vs Bakhat Rai and Co.	 the Madhya Pradesh High Court also took the same view as that of the Andhra Pradesh High Court while dealing with item 3	 Part II	 Schedule 1 of the C.P. and Berar Sales Tax Act. In the Madhya Pradesh case	 however	 the term 'oil seed ' has not been defined under the Act. The Court	 therefore	 held that since it was an item of every day use it must be construed in its popular meaning	 that is to say	 in that sense which people conversant with the subject matter with which the statute was dealing would attribute to it. The Division Bench of the Kerala High Court has also held in The Deputy Commissioner of Agricultural Income tax and Sales Tax	 Kozikode vs V. Sreedhara Shenoy that dhania (coriander) and methi are not oil seeds under section 14(vi) of the Central Act. Mr. Mahajan has strenuously submitted that the articles in question are spices to all indents and purposes and not "oil seeds". He further submits that even if they are oil seeds in the sense that these yield non volatile oil to a certain extent	 no evidence has been produced by the assessee that these are used for human consumption or in industry or in the manufacture of varnishes	 soaps and the like	 or in lubrication	 or in medicines	 perfumes	 cosmetics and the like as mentioned in the definition. Mr. Gobind Das	 on the other hand	 has drawn our attention to the fact that the High Court had before it the Condensed Chemical Dictionary (7th Edition) edited by Arther and Elizabeth Rose	 from which the following informations regarding the seeds in question were available: "Dhania (coriander seed); botanical name coriandrum sativem. Coriander oil is distilled from the coriander sativum a colourless or slightly yellowish	 liquid having aromatic odour. Jeera (cumin seed); Cumin oil is distilled from the cumin seed and is used for medicine	 flavouring and perfumery. It is a colourless or yellowish	 limpid liquid having characteristic odour of cumin. Postak (poppy seed); botanical name papover somniferum. Poppy oil is a very pale	 golden yellow liquid with pleasant taste and odour extracted from the seeds and it is used as food oil	 artist 's colours	 varnishes & lubrication. Methi (Fenugreek); botanical name trigonella Foenumgraecum (vide p. 164	 vol. 9 of the Encyclopaedia Britannica). It is stated inter alia therein that it bears a sickle shaped pod	 containing from 10 to 20 seeds	 from which 6% of a foetid	 fatty	 and bitter oil can be extracted by ether". Besides	 the High Court also had before it the notification of the Ministry of Finance	 Department of Economic Affairs	 Government of India	 dated January 3	 1959	 wherein amongst other commodities 970 the following were stated to be included in the term "oil seeds" under item (vi) of section 14 of the Central Act: "(18)Poppy seed (Posta dana	 Khaskhas); (37) Aniseed (saunf); (42) Coriander seeds (Dhania); (44) Cuminseed (Jeera	 Safed Jeera); (49) Fenugreek seeds (Methi)". Mr. Gobind Das also drew our attention to the Webster 's Third International Dictionary where coriander seed is described as "the ripened dried fruit of coriander used for flavouring especially of pickels	 curries	 confectioneries	 and liquors. " These appeals arise out of a decision in a reference under section 24 of the State Act under article 136 of the Constitution and we have to consider whether it is a fit case for interference with the order of the High Court when it held that the Sales Tax Tribunal was right in its conclusion. It is true the High Court has rightly observed that the aforesaid notification of the Government of India has no statutory force and as such is not binding on the Sales Tax Officer. It cannot	 however	 be denied that the Ministry of Finance	 Department of Economic Affairs	 is intimately conversant not only with the policy of legislation for the purpose of implementation of the provisions of the Central Act but is also familiar with the nature and quality of the commodities as also their use from time to time. If	 therefore	 such an authority issued a notification including certain commodities under the head of 'oil seeds '	 as defined under the Central Act	 it cannot be said that the Tribunal and the High Court were not right in preferring such an opinion of the Government as good evidence for its conclusion	 to the opinions relied upon by the Andhra Pradesh High Court on which great reliance has been placed by the appellant. A persual of the contents of the letters referred to in the judgment of the Andhra Pradesh High Court would indicate that the opinions cannot be said to be very firm or even final. Apart from this	 it is not known whether all the uses which are mentioned in the definition of "oil seeds" were brought to the notice of the National Chemical Laboratory	 Poona and of the Central Food Technological Research Institute	 Mysore	 in rendering their opinions. If	 therefore	 the Tribunal in the facts and circumstances of the case held that the particular commodities came within the definition of clause (vi) of section 14 of the Central Act	 it is not possible to hold that it was not right. The answer to the first question by the High Court is	 therefore	 rightly in the affirmative. We do not also see anything wrong in the High Court 's answering the second question in the way it did. The appeals	 therefore	 fail and are dismissed. There will be no order as to costs. We are thankful to Mr. Gobind Das for assisting the Court as amicus curaie. V.P.S. Appeals dismissed.

Under section 14(vi)	 	 among goods declared to be of special importance in inter State trade and commerce are mentioned oil seeds	 that is to say	 seeds yielding non volatile oils used for human consumption	 or in industry	 etc.	 or volatile oils used chiefly in medicines etc. The Assistant Commissioner under the Orissa Sales Tax Act	 the Tribunal	 and the High Court on reference	 held that jeera dhania	 panmohuri	 methi and postak are oil seeds within the meaning of section 14(vi) and liable to a lesser rate of tax. The High Court relied on ordinary and technical dictionaries and a notification of the Ministry of Finance	 Department of Economic Affairs	 Government of India	 dated January 3	 1959 for its conclusion. In appeal to this Court under article 136	 it was contended by the State	 relying on State of Andhra Pradesh vs Kajjam Ramchandraiah Gari Anantaiah (1961) 12 STC 795	 that the Court should adopt the meaning given to these articles in common parlance by people who use them	 that so understood they are spices and not oil seeds	 and that though they yield non volatile oil to a certain extent	 there is no evidence that they fall within the description in section 14(vi). Dismissing the appeal	 ^ HELD: It cannot be said that the Tribunal was not right	 and so it is not a fit case for interference under article 136	 when the High Court held that the Tribunal was right. [970C D	 G] (a) Item 3	 Schedule IV	 A.P. General Sales Tax Act	 1957	 is identical with section 14(vi) of the Central Act. In Kajjam Ramachandriah 's case	 the Andhra Pradesh High Court held that dhania did not come within the definition of oil seeds relying on some letters from (i) Director	 National Chemical Laboratory	 Poona	 and (ii) Central Food Technological Research Institute	 Mysore. [968F] (b) The High Court was right in the present case in holding that the notification of the Government of India had no statutory force and was not binding on the Sales Tax Officer	 but it cannot be said that the High Court and Tribunal were not right in preferring the opinion therein as good evidence for their conclusion to the opinions in the letters relied upon by the Andhra Pradesh High Court. The Ministry of Finance	 which issued the notification	 is intimately conversant not only with the policy of legislation for the purpose of implementation of the provisions of the Central Act	 but is also familiar with the nature and quality of the commodities and also their use from time to time. [970D F] (c) Further	 the letters of the Director	 National Chemical Laboratory and the Central Food Technological Research Institute	 do not indicate that the opinions expressed therein were firm or even final or whether all the uses mentioned in the definition of oil seeds were brought to their notice. [970F] Commissioner of Sales Tax	 Madhya Pradesh	 Indore vs Bakhat Rai and Co. (1966) 18 Sales Tax Cases 285 and The Deputy Commissioner of Agricultural Income tax and Sales Tax	 Kozhikode vs Sreedhara Shenoy (1973) 32 Sales Tax Cases 181	 referred to. 967