dissenting. I must respectfully dissent from the opinion delivered by the majority in this case. I feel that the majority have entirely missed the mark in reaching the conclusion which they have reached. In the first place, the answer to the question propounded by the Court of Appeals depends not so much on previous decisions of this court as upon proper interpretation of the 1964 Act (Ga. L. 1964, pp. 499, 598; Code Ann. § 88-1801, et seq.) referred to in the question. Previous decisions of this Court are relevant only insofar as they aid in a proper construction of the Act.
“In all interpretations [of legislative enactments], the courts shall look diligently for the intention of the General Assembly, keeping in view at all times, the old law, the evil, and the remedy.” Code § 102-102 (9). That this is the cardinal rule of statutory construction is so well established as to hardly require the citation of authority. See, however, for example, Foster v. Vickery, 202 Ga. 55, 60 (42 SE2d 117); and, Lamons v. Yarbrough, 206 Ga. 50, 55 (55 SE2d 551). I would look first to the proper construction of the law involved to determine the legislative intent as to whether the property referred to in the question is exempt. The hospital Authority involved in this case is one created under the provisions of Ch. 88-18 of the Code as enacted by the Act approved March 18, 1964 (Ga. L. 1964, pp. 499-664). Chapter 88-18, commonly referred to as the “Hospital Authority Law,” begins on p. 598 of Ga. L. 1964; 'Code Ann. § 88-1803, contains the exemption with which we are concerned in this case. That exemption, omitting certain irrelevant provisos added thereto by the Act of 1965 (Ga. L. 1965, p. 347), reads as follows: “Hospital Authorities shall be granted the same exemptions and exclusions from taxes as are now granted to cities and counties for the operation of facilities similar to facilities to be operated by hospital Authorities as provided for under the provisions of this title.” *540(Emphasis supplied). I find no definition of the word “facilities” set forth in this chapter of the Act. However, § 88-1802 (d) reads as follows: “The word ‘project’ includes the acquisition and construction of hospitals, sanitariums, dormitories, clinics, housing accommodations, nursing homes, rehabilitation centers, extended care facilities and other public health facilities for the use of patients and officers and employees of any institution under the supervision and control of any hospital Authority or leased by the hospital Authority for operation by others to promote the public health needs of the community and all utilities and facilities deemed by the Authority necessary or convenient for the efficient operation thereof.”
In giving consideration to this language in its context, I cannot ascribe to the legislature an intent to exempt from ad valorem taxation any facility other than those enumerated in Par. (d) of § 88-1802 above quoted. Conceding that, in answering the question propounded, we may be bound to look only to the question itself in formulating our answer, and therefore we may not judicially know or take into consideration the exact nature or kind of property here involved, I do not think we should give an unqualified affirmative answer to the question. The question clearly states that the property involved is not itself a part of the hospital but is property, the income from which is devoted to hospital operations and in furtherance of the legitimate functions of the hospital Authority. If the property involved cannot be logically classified as a hospital, sanitarium, dormitory, clinic, housing accommodation, nursing home, rehabilitation center, extended care facility or other public health facility created for the use of patients, officers and employees of the institution involved, then it cannot come within the exemption granted.
It seems to me that several fundamental rules of statutory construction in addition to the ones alluded to above strongly militate against the conclusion reached by the majority of my associates. Hospital Authorities created under the 1964 Act are expressly made corporate bodies with authority to sue and be sued. They are nothing more or less than public non-profit corporations created for the specific purposes set forth in the *541Act. Smith v. Board of Educ. of Washington County, 153 Ga. 758 (2) (113 SE 147). As such, the powers and rights granted to them under the Act are to be strictly construed and not to be extended by implication. Ga. Railroad v. Smith, 70 Ga. 694, 702; Alabama Great Southern R. v. Gilbert, 71 Ga. 591; West End & Atlanta Street R. Co. v. Atlanta Street R. Co., 49 Ga. 151 (2); Augusta & Savannah R. Co. v. Augusta Southern R. Co., 96 Ga. 562, 565 (23 SE 501); City of Macon v. Walker, 204 Ga. 810, 812 (51 SE2d 633).
Furthermore, we are here dealing with a provision of the statute exempting hospital Authorities from the payment of taxes. A fundamental principle of tax exemptions is that they shall be strictly construed against the taxpayer, and unless the language of the statute clearly grants the exemption, it is the duty of the court to rule in favor of the State. Fulton County Fed. Savings &c. Assn. v. Simmons, 210 Ga. 621, 624 (82 SE2d 16) and cits.
Another proposition of law which I deem to be applicable to this question is the maxim, “expressio unius est exclusio alterius.” City of Macon v. Walker, 204 Ga. 810 (2), supra. Here the legislature has seen fit to exempt specified properties from taxation, to wit, facilities operated by hospital Authorities. As we have already pointed out, these facilities are strictly related to hospitals and their immediate appurtenant structures. Nothing else was exempted by the legislature and under the maxim just quoted no other exemption will be implied.
Finally, it must be noted that the legislature did not intend to treat the property of hospital authorities as public property so as to bring all property held by hospital Authorities within the purview of Code Ann. § 92-201 exempting all public property. To me this is manifest from the language of § 88-1808 relating to the character of certificates of indebtedness of the Authority. That section provides that the certificates and other obligations of a hospital authority shall not be a debt of a city, county, or of the State of Georgia nor of any political subdivision thereof nor an indebtedness of any combination of subdivisions acting jointly under the provisions of the Act. That section declares, however, that such certificates and the income *542therefrom shall be exempt from all taxes because they are issued for an essential public and governmental purpose. Hospital Authorities are not political subdivisions of the State, however, and their property, while devoted to those purposes, is not per se public property.
Nevertheless, it is contended that the general exemption from taxes of all public property embodied in Code Ann. § 92-201 is applicable to the property of hospital Authorities. The complete answer to such contention is found in the wording of § 88-1803 above referred to. That section is in irreconcilable conflict with the provisions of § 92-201 insofar as § 92-201 provides for a tax exemption to property of hospital Authorities as “public property,” because Code Ann. § 88-1803 spells out exactly what property of hospital Authorities is exempt. While I recognize the well established rule that repeals by implication are not favored, and that there is no express repeal in any part of § 92-201; yet, as was said by this court, speaking through then Justice (now Chief Justice) Almand in the case of Nash v. National Preferred Life Ins. Co., 222 Ga. 14, 21 (148 SE2d 402): “The law applicable to repeal by implication is well settled in this State. While repeal by implication is not favored, a statute will be held to have repealed a prior statute where the latter is clearly inconsistent and contrary to the most recently enacted law or where the later enactment appears to cover the entire subject matter and give expression to the whole law on the subject. Leonard v. State ex rel. Lanier, 204 Ga. 465 (2) (50 SE2d 212); Collier v. Mitchell, 207 Ga. 528, 530 (63 SE2d 338). The repeal will be effective only insofar as there is inconsistency between the two statutes. McGregor v. Clark, 155 Ga. 377, 385 (116 SE 823); Atlantic Log &c. Co. v. Central of Ga. R. Co., 171 Ga. 175 (155 SE 525), and cases there cited. . . . In the final analysis, however, the intention of the legislature will control the question as to repeal by implication. Western & A. B. Co. v. City of Atlanta, 113 Ga. 537, 556 (38 SE 996, 54 LRA 298); Jones v. Stokes, 145 Ga. 745, 749 (89 SE 1078).”
As I have already said, I think it is clear that the intention of the legislature was to limit the tax exemption to be afforded *543to hospital Authorities to those facilities used for hospital and related purposes. Applying the foregoing rule to the enactment here in question, it is clear, there being a general repealer appended to the Act (Ga. L. 1964, p. 664), that the legislature intended to repeal § 92-201 insofar as it would afford a general exemption from taxes to the property of hospital Authorities as “public property.”
For the foregoing reasons, I most respectfully dissent from the answer made by the majority of this court to the question propounded by the Court of Appeals. I would, at the very least, modify the answer so as to qualify the unequivocal affirmative reply by limiting its application to those facilities operated by the hospital Authority as a hospital, sanitarium, dormitory, clinic, housing accommodation, nursing home, rehabilitation center, extended care facility or other public health facility, maintained for the use of patients, officers and employees of the hospital authority. To the extent that the answer may be construed and applied so as to afford an exemption from ad valorem taxes of any real property owned by the hospital not within these limited categories I think it is wrong.