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The Madras High Court had to consider the question whether iron hairpins can be included within the meaning of “toilet requisites” in entry 51 of the First Schedule of the Madras General Sales Tax Act, 1959, which was in the following terms :
“Scents and perfumes, powders, snows, scented hair-oils, scented sticks, cosmetics and toilet requisites, except soaps.”
The Division Bench pointed out that all the articles in item 51 are intended to be rubbed, poured, sprinkled or sprayed or introduced into or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness or appearance. Thus, there was a category of things preceding the words “toilet requisites”, and therefore, the doctrine of ejusdem generis had to be applied to interpret the words “toilet requisites” as referring to the words of the same kind or nature and not intended to extend to objects of a wholly different kind, It was, therefore, held that a hairpin could not be treated as of the same category, as it could not be used either for cleansing or beautifying the body. It is only used for holding the hair.
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