company with the earlier one's exemption from
taxation.[1667]

Furthermore, an exemption from taxation is to be strictly construed
even in the hands of one clearly entitled to it. So the exemption
conferred by its charter on a railway company was held not to extend to
branch roads constructed by it under a later statute.[1668] Also, a
general exemption of the property of a corporation from taxation was
held to refer only to the property actually employed in its
business.[1669] Also, the charter exemption of the capital stock of a
railroad from taxation "for ten years after completion of the said road"
was held not to become operative until the completion of the road.[1670]
So also the exemption of the campus and endowment fund of a college was
held to leave other lands of the college, though a part of its
endowment, subject to taxation.[1671] Likewise, provisions in a statute
that bonds of the State and its political subdivisions are not to be
taxed and shall not be taxed were held not to exempt interest on them
from taxation as income of the owners.[1672]

Strict Construction and the Police Power.--The police power,
too, has frequently benefited from the doctrine of strict construction,
although, for a reason pointed out below, this recourse is today seldom,
if ever, necessary in this connection. Some of the more striking cases
may be briefly summarized. The provision in the charter of a railway
company permitting it to set reasonable charges still left the
legislature free to determine what charges were reasonable.[1673] On the
other hand, when a railway agreed to accept certain rates for a
specified period, it thereby foreclosed the question of the
reasonableness of such rates.[1674] The grant to a company of the right
to supply a city with water for twenty-five years was held not to
prevent a similar concession to another company by the same city.[1675]
The promise by a city in the charter of a water company not to make a
similar grant to any other person or corporation was held not to prevent
the city itself from engaging in the business.[1676] A municipal
concession to a water company which was to run for thirty years and
which was accompanied by the provision that the "said company shall
charge the following rates," was held not to prevent the city from
reducing such rates.[1677] But more broadly, the grant to a municipality
of the power to regulate the charges of public service companies was
held not to bestow