The opinion of the court was delivered by
Foth, C.:
The issue in this case is whether the Kansas commission on civil rights has the authority to entertain and investigate a complaint charging a city police officer with an unlawful discriminatory practice, based on the officer’s decision to arrest the com[249]*249plainant and on the treatment afforded the complainant during the arrest and the time he is in custody.
On August 1, 1972, Wayne A. Lewis filed such a complaint with the commission, naming as respondents the Topeka police department and one of its officers. In it he identified himself as a black American who worked and attended Topeka High School as a junior. He recounted an incident in which he alleged in substance: The officer followed him from a gasoline station in a patrol car and stopped his car with no reason; after checking Lewis’ driver’s license and car tags and finding them legal, the officer called him names, offered to fight him, and shone a flashlight in his eyes in an harassing manner; upon finding Lewis with his eyeglasses in his hands the officer arrested him for violating a license restriction requiring him to wear glasses when driving. Upon arriving at the police station, Lewis alleged, the officer twisted the skin on his back, called him names and indulged in racial slurs. Other officers joined in taunting, threatening and insulting him, he said. He concluded his complaint by stating:
“I hereby charge the Topeka Police Department and its representatives with violation of the Kansas Act Against Discrimination in that I was denied the full and equal use of their services and advantages because of my race.”
A copy was served on the respondent officer and the Topeka police department, and the commission undertook to investigate the complaint. On September 10, 1973, it served a subpoena on the Topeka chief of police seeking the personnel and arrest records of the respondent officer, the disposition of the department’s restricted driver’s license arrests for a two year period, and the duty roster for the day of the alleged incident. When the records asked for were not forthcoming the commission obtained under K. S. A. 44-1004 (5) an ex parte order from the Shawnee county district court compelling production.
The police department responded with a motion to suppress, asserting that the commission had no jurisdiction over the subject matter of the complaint or to issue the subpoena, and therefore the court had no jurisdiction to enter its enforcement order.
Upon first consideration the trial court agreed with the respondents, finding that the complaint “does not allege acts which come within the purview and jurisdiction of the Kansas Commission on Civil Rights, because K. S. A. 1972 Supp. 44-1009 (c) (3) relates to unlawful employment practices.” The commission filed a motion to reconsider which was sustained. The trial court reversed its po[250]*250sition, found that the process of making an arrest is covered by the act, and ordered the chief of police to comply with the subpoena forthwith. The respondents have appealed, and the compliance order was stayed pending the appeal.
We are not concerned in this case with the truth of the complaint. We are only concerned with whether the nature of its allegations are such as to give the commission jurisdiction to investigate it.
It appears settled that the commission s jurisdiction to investigate a complaint depends on whether it alleges a violation of the Kansas act against discrimination. Thus, in Kansas Commission on Civil Rights v. Sears, Roebuck & Co., 216 Kan. 306, 532 P. 2d 1263, the commission had received a complaint from one William V. Minner alleging discrimination in the extension of retail credit. At issue was the commission s authority to investigate the complaint by way of subpoena. The first question to be answered, the court said, was: “Do the provisions of the Act apply to the area of consumer credit practices in a retail merchandising establishment? If such practices are not encompassed by the Act the commission would lack authority to investigate Minner’s complaint or to issue the subpoena.” (Id., at 310.)
The real question, then, is whether the act covers governmental conduct in areas other than employment, public accommodations and housing. The court has concluded that it does not.
The policy of the state and the purposes of the act are set forth in K. S. A. 1974 Supp. 44-1001:
“This act shall be known as the Kansas act against discrimination. It shall be deemed an exercise of the police power of the state for the protection of the public welfare, safety, health and peace of the people of this state. The practice or policy of discrimination against individuals in employment relations, in relation to free and public accommodations or in housing by reason of race, religion, color, sex, physical handicap, national origin or ancestry is a matter of concern to the state, since such discrimination threatens not only the rights and privileges of the inhabitants of the state of Kansas but menaces the institutions and foundations of a free democratic state. It is hereby declared to be the policy of the state of Kansas to eliminate and prevent discrimination in all employment relations, to eliminate and prevent discrimination, segregation, or separation in all places of public accommodations covered by this act, and to eliminate and prevent discrimination, segregation or separation in housing.
“It is also declared to be the policy of this state to assure equal opportunities and encouragement to every citizen regardless of race, religion, color, sex, physical handicap, national origin or ancestry, in securing and holding, without discrimination, employment in any field of work or labor for which he is properly qualified, to assure equal opportunities to all persons within this state to full [251]*251and equal public accommodations, and to assure equal opportunities in housing without distinction on account of race, religion, color, sex, physical handicap, national origin or ancestry. It is further declared that the opportunity to secure and to hold employment, the opportunity for full and equal public accommodations as covered by this act and the opportunity for full and equal housing are civil rights of every citizen.
“To protect these rights, it is hereby declared to be the purpose of this act to establish and to provide a state commission having power to eliminate and prevent segregation and discrimination, or separation in employment, in all places of public accommodations covered by this act, and in housing because of race, religion, color, sex, physical handicap, national origin or ancestry, either by employers, labor organizations, employment agencies, realtors, financial institutions or other persons as hereinafter provided.” (Emphasis added.)
It will be seen that the legislature mentions the three areas of coverage (employment, public accommodations and housing) no less than five times in its statement of policy and purpose. In addition, when conferring specific powers on the commission in K. S. A. 1974 Supp. 44-1004 it provided:
“The commission shall have the following functions, powers and duties:
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The opinion of the court was delivered by
Foth, C.:
The issue in this case is whether the Kansas commission on civil rights has the authority to entertain and investigate a complaint charging a city police officer with an unlawful discriminatory practice, based on the officer’s decision to arrest the com[249]*249plainant and on the treatment afforded the complainant during the arrest and the time he is in custody.
On August 1, 1972, Wayne A. Lewis filed such a complaint with the commission, naming as respondents the Topeka police department and one of its officers. In it he identified himself as a black American who worked and attended Topeka High School as a junior. He recounted an incident in which he alleged in substance: The officer followed him from a gasoline station in a patrol car and stopped his car with no reason; after checking Lewis’ driver’s license and car tags and finding them legal, the officer called him names, offered to fight him, and shone a flashlight in his eyes in an harassing manner; upon finding Lewis with his eyeglasses in his hands the officer arrested him for violating a license restriction requiring him to wear glasses when driving. Upon arriving at the police station, Lewis alleged, the officer twisted the skin on his back, called him names and indulged in racial slurs. Other officers joined in taunting, threatening and insulting him, he said. He concluded his complaint by stating:
“I hereby charge the Topeka Police Department and its representatives with violation of the Kansas Act Against Discrimination in that I was denied the full and equal use of their services and advantages because of my race.”
A copy was served on the respondent officer and the Topeka police department, and the commission undertook to investigate the complaint. On September 10, 1973, it served a subpoena on the Topeka chief of police seeking the personnel and arrest records of the respondent officer, the disposition of the department’s restricted driver’s license arrests for a two year period, and the duty roster for the day of the alleged incident. When the records asked for were not forthcoming the commission obtained under K. S. A. 44-1004 (5) an ex parte order from the Shawnee county district court compelling production.
The police department responded with a motion to suppress, asserting that the commission had no jurisdiction over the subject matter of the complaint or to issue the subpoena, and therefore the court had no jurisdiction to enter its enforcement order.
Upon first consideration the trial court agreed with the respondents, finding that the complaint “does not allege acts which come within the purview and jurisdiction of the Kansas Commission on Civil Rights, because K. S. A. 1972 Supp. 44-1009 (c) (3) relates to unlawful employment practices.” The commission filed a motion to reconsider which was sustained. The trial court reversed its po[250]*250sition, found that the process of making an arrest is covered by the act, and ordered the chief of police to comply with the subpoena forthwith. The respondents have appealed, and the compliance order was stayed pending the appeal.
We are not concerned in this case with the truth of the complaint. We are only concerned with whether the nature of its allegations are such as to give the commission jurisdiction to investigate it.
It appears settled that the commission s jurisdiction to investigate a complaint depends on whether it alleges a violation of the Kansas act against discrimination. Thus, in Kansas Commission on Civil Rights v. Sears, Roebuck & Co., 216 Kan. 306, 532 P. 2d 1263, the commission had received a complaint from one William V. Minner alleging discrimination in the extension of retail credit. At issue was the commission s authority to investigate the complaint by way of subpoena. The first question to be answered, the court said, was: “Do the provisions of the Act apply to the area of consumer credit practices in a retail merchandising establishment? If such practices are not encompassed by the Act the commission would lack authority to investigate Minner’s complaint or to issue the subpoena.” (Id., at 310.)
The real question, then, is whether the act covers governmental conduct in areas other than employment, public accommodations and housing. The court has concluded that it does not.
The policy of the state and the purposes of the act are set forth in K. S. A. 1974 Supp. 44-1001:
“This act shall be known as the Kansas act against discrimination. It shall be deemed an exercise of the police power of the state for the protection of the public welfare, safety, health and peace of the people of this state. The practice or policy of discrimination against individuals in employment relations, in relation to free and public accommodations or in housing by reason of race, religion, color, sex, physical handicap, national origin or ancestry is a matter of concern to the state, since such discrimination threatens not only the rights and privileges of the inhabitants of the state of Kansas but menaces the institutions and foundations of a free democratic state. It is hereby declared to be the policy of the state of Kansas to eliminate and prevent discrimination in all employment relations, to eliminate and prevent discrimination, segregation, or separation in all places of public accommodations covered by this act, and to eliminate and prevent discrimination, segregation or separation in housing.
“It is also declared to be the policy of this state to assure equal opportunities and encouragement to every citizen regardless of race, religion, color, sex, physical handicap, national origin or ancestry, in securing and holding, without discrimination, employment in any field of work or labor for which he is properly qualified, to assure equal opportunities to all persons within this state to full [251]*251and equal public accommodations, and to assure equal opportunities in housing without distinction on account of race, religion, color, sex, physical handicap, national origin or ancestry. It is further declared that the opportunity to secure and to hold employment, the opportunity for full and equal public accommodations as covered by this act and the opportunity for full and equal housing are civil rights of every citizen.
“To protect these rights, it is hereby declared to be the purpose of this act to establish and to provide a state commission having power to eliminate and prevent segregation and discrimination, or separation in employment, in all places of public accommodations covered by this act, and in housing because of race, religion, color, sex, physical handicap, national origin or ancestry, either by employers, labor organizations, employment agencies, realtors, financial institutions or other persons as hereinafter provided.” (Emphasis added.)
It will be seen that the legislature mentions the three areas of coverage (employment, public accommodations and housing) no less than five times in its statement of policy and purpose. In addition, when conferring specific powers on the commission in K. S. A. 1974 Supp. 44-1004 it provided:
“The commission shall have the following functions, powers and duties:
“(4) To receive, initiate, investigate, and pass upon complaints alleging discrimination in employment, public accommodations and housing because of race, religion, color, sex, physical handicap, national origin or ancestry.” (Emphasis added.)
Our previous decisions construing the act have assumed that its coverage was limited to those three areas. See, e. g., Jarvis v. Kansas Commission on Civil Rights, 215 Kan. 902, 903, 528 P. 2d 1232; Atchison, T. & S. F. Rly. Co. v. Commission on Civil Rights, 215 Kan. 911, 916-17, 529 P. 2d 666; Atchison, T. & S. F. Rly. Co. v. Lopez, 216 Kan. 108, 113, 531 P. 2d 455.
In support of its claim of jurisdiction here the commission relies on a 1972 amendment to the act’s definition of the term “unlawful discriminatory practice.” Prior to the 1972 amendment, K. S. A. 44-1002 (i) defined an unlawful discriminatory practice as discrimination or segregation in some twenty-one specific types of business establishment or facility, or in “a place of public accommodations covered by this act.” The 1972 amendment (L. 1972, ch. 194, § 2) added the following language:
“The term ‘unlawful discriminatory practice’ also means any discrimination against persons in the full and equal use and enjoyment of the services, facili[252]*252ties, privileges and advantages of any institution, department or agency of the state of Kansas or any political subdivision or municipality thereof.”
By the same act virtually the identical language was also added to K. S. A. 44-1009 (L. 1972, ch. 194, § 7). As amended, the section reads:
“(c) It shall be an unlawful discriminatory practice:
“(3) For any person, as defined herein, to refuse, deny, make a distinction, directly or indirectly, or discriminate in any way against persons because of the race, religion, color, sex, national origin or ancestry of such persons in the full and equal use and enjoyment of the services, facilities, privileges and advantages of any institution, department or agency of the state of Kansas or any political subdivision or municipality thereof.”
On the face of it it might appear that this language extended the act’s coverage to the “services, facilities, privileges and advantages” of a governmental agency in any area of activity. But, “[i]n order to ascertain the legislative intent, courts are not permitted to consider only a certain isolated part or parts of an act but are required to consider and construe together all parts thereof in pari materia. When the interpretation of some one section of an act according to the exact and literal import of its words would contravene the manifest purpose of the legislature, the entire act should be construed according to its spirit and reason, disregarding so far as may be necessary the strict letter of the law.” (Claflin v. Walsh, 212 Kan. 1, 8, 509 P. 2d 1130. Emphasis added.) See also, cases collected in 9 West’s Kansas Digest, Statutes, § 205, and 5 Hatcher’s Kansas Digest (Rev. Ed.), Statutes, § 77.
Construing the act as a whole, the court is unable to find from the 1972 amendment any legislative intent to extend the scope of the act 'beyond those three areas which are stated and restated ¡to be the areas of primary legislative concern. The amendment is equally susceptible, in the court’s view, of being interpreted as a clarifying measure, designed to make clear that governmental as well as private action is covered in the three areas covered by the act.
At best the amendment appears to the court to be ambiguous. If by these two small amendments the legislature intended to extend the act and the commission’s jurisdiction into an area previously foreclosed, more appropriate and explicit language could and should have been employed. If a wholly new purpose was meant to be added to the act, 44-1001 could easily have been amended to say so. [253]*253The prior history of the act reflects a relatively consistent legislative pattern of enacting such amendments each time a new area was added to the act’s coverage. (The history of such previous extensions is recounted in Kansas Commission on Civil Rights v. Sears, Roebuck & Co., supra.) The failure to amend the “purpose” section to include the claimed new purpose involved here appears to the court persuasive evidence that no such legislative intent existed.
The result is a holding that the act does not cover, and the commission has no authority to investigate, governmental activities which do not involve employment relations, public accommodations or housing.
The question remains whether a discriminatory arrest, as alleged here, falls into any of those three categories. It seems apparent that employment and housing are not involved. Neither, in the court’s view, is such a police function a matter of “public accommodation.” K. S. A. 44-1002 (h), (now L. 1975, ch. 264, § 1 [A]) limits “public accommodations” covered by the act to:
“. . . [A]ny person as defined herein, who caters or offers goods, services, facilities, and accommodations to the public, but shall not include a nonprofit fraternal or social association or corporation.”
In Kansas Commission on Civil Rights v. Sears, Roebuck & Co., supra, this court discussed at length the meaning of the term “public accommodations,” which is generally interpreted to mean:
“. . . [T]hose places which are held out as open to the general public and which members of the public generally are invited to patronize and otherwise visit.” (216 Kan. at 313.)
The public is not invited to “patronize or otherwise visit” a municipal police department in the sense the term is used in the Act. A police department’s law enforcement activities are therefore beyond the investigatory jurisdiction of the commission.
Finally, it may be noted that the parties devoted a large portion of their respective briefs to the question of whether an arrest is a “service” of the police department, so that if it is discriminatorily made it would be an unlawful discriminatory practice. The question is not free from difficulty. However, in view of the court’s disposition of the case it need not be decided at this time.
The judgment is reversed and the case is remanded with directions to set aside the enforcement order and quash the subpoena.
APPROVED BY THE COURT.
Miller, J., not participating.