STATE OF BIHAR vs SHREE BAIDYANATH AYURVEDBHAWAN(P)LTD&ORS

The Supreme Court addressed the legislative competence of the State Legislature regarding the definition of 'intoxicant' in Section 2(12a) of the Bihar Excise Act, 1915, as amended by Bihar Amending Act No.6 of 1985. The Court upheld the High Court's ruling that the inclusion of 'medicinal and toilet preparations' containing alcohol was unconstitutional, as it conflicted with the Medicinal & Toilet Preparations (Excise Duties) Act, 1955, and violated Article 301 and Article 14 of the Constitution. The Court concluded that the State's actions constituted a colorable exercise of power and were discriminatory, thus affirming the High Court's decision to invalidate the notifications issued under the Bihar Act.