KERWIN,
J.:—The
neat
point
for
determination
in
these
appeals
is
whether
the
sheets
published
by
the
respondents
fall
within
the
meaning
of
the
word
‘‘newspapers’’
as
used
in
Schedule
III
of
the
Special
War
Revenue
Act.
While
the
appellant
seeks
judgment
for
certain
amounts
for
sales
tax
in
various
years,
the
provisions
of
the
Act
applicable
may
be
taken
to
be
sees.
85,
86
and
89
of
R.S.C.,
1927,
ch.
179.
Sec.
85
(f)
provides
that
in
part
XIII
of
the
Act
"producer
or
manufacturer’’
shall
include
"‘any
printer,
publisher,
lithographer
or
engraver’’.
By
sec.
86,
a
consumption
or
sales
tax
is
imposed
on
the
sale
price
of
all
goods
(a)
produced
or
manufactured
in
Canada
payable
by
the
producer
or
manufacturer.
Subsee.
1
of
sec.
89
is
as
follows
:—
4
The
tax
imposed
by
this
Part
shall
not
apply
to
the
sale
or
importation
of
the
articles
mentioned
in
Schedule
III
of
this
Act.”’
Schedule
III
referred
to,
includes
"
"
newspapers
and
quarterly-monthly,
bi-monthly
and
semimonthly
magazines
and
weekly
literary
papers
unbound.”
For
some
years
the
Montreal
Stock
Exchange
and
later
the
Exchange
Printing
Company
printed,
about
noon
of
each
day
that
the
Exchange
was
in
session,
a
sheet
showing
the
transactions
on
the
Exchange
during
the
morning,
and
in
the
afternoon
a
similar
record
of
the
transactions
for
the
remainder
of
the
day.
In
like
manner
were
published
the
transactions
on
the
Montreal
Curb
market.
Each
week
was
printed
a
‘‘comparative
review
of
transactions’’
on
the
Exchange
and
a
‘‘comparative
review
of
transactions’’
on
the
Curb.
These
sheets
from
time
to
time
contained
notices
of
dividends,
annual
meetings
and
the
loss
of
certificates,
in
connection
with
companies
whose
stock
was
listed
on
the
Exchange.
The
weekly
publications
besides
summaries
of
the
week’s
business,
contained
a
tabulation
comparing
the
business
of
that
particular
week
with
the
business
of
the
corresponding
week
in
the
previous
year.
The
members
of
the
Exchange
formed
the
greater
bulk
of
the
users
of
these
sheets
for
which
they
paid
on
a
sliding
scale
but
copies
were
also
exchanged
with
similar
institutions
in
Canada
and
the
United
States.
Some
were
sold
to
outsiders
and
the
result
of
the
evidence
of
the
acting
secretary-treasurer
of
the
Exchange
is
that
any
member
of
the
public
might
become
a
subscriber.
The
term
newspapers
”
is
not
defined
in
the
Act
and
while
we
were
referred
to
various
definitions
in
other
Dominion
and
provincial
statutes,
the
statement
of
the
present
Chief
Justice,
in
delivering
the
judgment
of
the
Court
in
Mun-Bingham
Printing
Co.
Limited
v.
The
King
[1930]
8.C.R.
282
at
p.
283
is
peculiarly
appropriate.
"The
usage
of
that
word
in
other
statutes
may
be
looked
at,
if
the
other
statute
happens
to
be
in
pari
materia,
but
it
is
altogether
a
fallacy
to
suppose
that
because
two
statutes
are
in
pari
materia,
a
definition
in
one
can
be
bodily
transferred
to
the
other.
.
.
.’’
In
the
instant
case,
the
word
under
discussion
is
not
defined
in
any
statute
in
pari
materia
and
it
remains
only
to
give
to
it
the
ordinary
meaning
that
it
usually
bears.
Webster’s
New
International
Dictionary
may
be
taken
as
giving
a
definition
of
"newspaper’’
which
is
expressed
in
corresponding
terms
in
other
well
recognized
dictionaries
:-—
4
‘a
paper
printed
and
distributed
at
stated
intervals
.
.
.
to
convey
news
.
.
.
and
other
matters
of
public
interest.”
The
sheets
in
question
meet
these
requirements;
the
mere
fact
that
any
particular
publication
is
meant
to
interest
only
a
section
of
the
public
does
not
limit
the
meaning
of
the
expression
as
a
reference
to
religious
or
fraternal
publications
will
at
once
make
clear.
The
sheets
in
question
contain
not
merely
a
record
of
transactions
on
the
Exchange
or
curb
market
but
also
information
to
those
desiring
it
as
to
such
transactions
;
and
the
other
items
from
time
to
time
included
give
‘‘tidings,
new
information,
fresh
events
reported,’’
(vide
Concise
Oxford
Dictionary
defining
‘‘news’’).
Being
of
opinion
that
the
publications
are
newspapers
for
the
purposes
of
the
Special
War
Revenue
Act,
the
respondents
have
brought
themselves
within
the
language
of
an
exempting
proviso.
Dominion
Press
Limited
v.
Minister
of
Customs
and
Excise
[1928]
A.C.
340.
The
appeals
will,
therefore,
be
dismissed
with
costs.
Appeals
dismissed.
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