The impugned Act does not completely debar publication of 'note–books', it only provides that a 'note–book' may be published either by the Board itself or under the authority of it in the same way as text–books are approved or prepared and published by it for schools. Bangladesh National Curriculum and Textbook Board vs AM Shamsuddin 48 DLR (AD) 184.

A 'note book' is nothing more than a 'text book' put in a different but material form. It is not an expression of ideas or opinions with regard to the contents of the text­book, but it is merely a presentation of the same text book in a different manner. The impugned Act by putting the restriction on printing, publishing, etc of note books may well be construed as imposing reasonable restriction permissible under Article 39 (2). Bangladesh National Curriculum and Textbook Board vs AM Shamsuddin 48 DLR (AD) 184.