might easily become a bar to the development of transportation along new
lines.[1661]

Applications of the Strict Construction Rule.--The rule of
strict construction has been reiterated by the Court many times. A good
illustration is afforded by the following passage from its opinion in
Blair _v._ Chicago,[1662] decided nearly seventy years after the Charles
River Bridge Case: "Legislative grants of this character should be in
such unequivocal form of expression that the legislative mind may be
distinctly impressed with their character and import, in order that the
privileges may be intelligently granted or purposely withheld. It is a
matter of common knowledge that grants of this character are usually
prepared by those interested in them, and submitted to the legislature
with a view to obtain from such bodies the most liberal grant of
privileges which they are willing to give. This is one among many
reasons why they are to be strictly construed. * * * 'The principle is
this, that all rights which are asserted against the State must be
clearly defined, and not raised by inference or presumption; and if the
charter is silent about a power, it does not exist. If, on a fair
reading of the instrument, reasonable doubts arise as to the proper
interpretation to be given to it, those doubts are to be solved in favor
of the State; and where it is susceptible of two meanings, the one
restricting and the other extending the powers of the corporation, that
construction is to be adopted which works the least harm to the
State.'"[1663]

Strict Construction of Tax Exemptions.--An excellent
illustration of the operation of the rule in relation to tax exemptions
is furnished by the derivative doctrine that an immunity of this
character must be deemed as intended solely for the benefit of the
corporation receiving it and hence may not, in the absence of express
permission by the State, be passed on to a successor.[1664] Thus, where
two companies, each exempt from taxation, were permitted by the
legislature to consolidate the new corporation was held to be subject to
taxation.[1665] Again, a statute which granted a corporation all "the
rights and privileges" of an earlier corporation was held not to confer
the latter's "immunity" from taxation.[1666] Yet again, a legislative
authorization of the transfer by one corporation to another of the
former's "estate, property, right, privileges, and franchises" was held
not to clothe the later