BENEFICIAL INTERPRETATION IN WELFARE LEGISLATION: STUDY OF

JUDICIAL DECISIONS IN INDIA INTRODUCTION

A beneficial legislation is a statute which purports to confer a benefit on individuals or a class of
persons. The nature of such benefit is to relieve said persons of onerous obligations under
contracts entered into by them. Further individuals with whom they stand in certain relations may
attempt to perpetrate oppressive acts upon the vulnerable party and a beneficial legislation tends
to protect them in such instances.1 When a statute is interpreted liberally and is given the widest
possible meaning which the language permits it is known as Beneficial Interpretation. When a
statute is meant for the benefit of a particular class and if a word in the statute is capable of two
meanings i.e. one which would preserve the benefits and one which would not, then the meaning
that preserves the benefit must be adopted.2Beneficial construction is an interpretation to secure
remedy to the victim who is unjustly denied of relief. The interpretation of a statue should be
done in such a way that mischief is suppressed and remedy is advanced.3 GOVERNING
PRINCIPLES In order to interpret a statute beneficially three important principles should be
followed:
 Words in the statute should be interpreted in its widest form but only to the extent which the
language permits or contains.
 The most complete remedy which a particular provision intends should be given.
 A statute should always purport to confer benefits on particular class or category for which the
beneficial legislation is intended.

In construing welfare legislation following steps should be adopted

 liberal approach should be adopted, and

Purposive construction which would effectuate the object of the welfare legislation should be
given to the expressions used in the statute
As welfare statues are aimed at protection and promotion of social and economic well being of
its citizen they should be construed widely and liberally. Such statutes should be interpreted in
such a way that the power conferred by them is achieved and benefits the particular class or
category of people for whom it was intended by the legislature.5 Therefore it becomes the duty
of the court to interpret a provision, especially a welfare statute by giving it a wider meaning
rather than a restrictive meaning. BENEFICIAL CONSTRUCTION OF WELFARE
STATUTE
Industrial Disputes Act 1947 is one of welfare statute which intends to bring about peace and
harmony between management and labour in an industry and improve the service conditions of
industrial workers which in will turn accelerate productive activity of the country resulting in its
prosperity As a result the prosperity of the country in turn will help to improve the conditions of
the workmen. Therefore this statute should be interpreted in such a way that it advances the
object and the purpose of the legislation and gives it a full meaning and effect so that the ultimate
social objective is achieved. The courts while interpreting labour laws have always stressed on
the doctrine of social justice as enshrined in the Preamble of Constitution. There are certain
provisions which can also be seen as beneficial to a particular class which is defined in Industrial
Dispute Act i.e. industry, workman, industrial disputes etc.
The word „industry‟ is defined in Section 2(j) and is the most crucial definition in the Industrial
Dispute Act, 1947. Since this statute is welfare legislation the word „industry‟ should be given a
wider meaning. The interpretation of this term has varied from time to time and has been in
controversy. Earlier in 1953 , Supreme Court held in the case of DN Banerji v PR Mukherjee
AIR 1953 SC 58 that though municipal activity cannot be regarded as trade or business adventure
but will fall within the expression „undertaking‟ and would be considered an industry.
However, later in 1970, In Sufdarjung Hospital case (Safdarjung Hospital v Kuldip Sethi , AIR
1970 SC 1407) court held that the definition of the term industry should not be read in two parts
but rather read as a whole because a collective enterprise exists only when there is a relationship
between employers and employees where the former relies upon the services of the latter to
fulfill their own occupation. It was held that hospitals run by the Government or Charitable
Institutions are not run on commercial lines and further the hospital in question is not industry as
it does not run on terms analogous to trade or business. Thus interpretation of term industry was
narrowed in this case.
INTERPRETATION OF THE CONSTITUTION (which is also a welfare legislation)
A constitution is the fundamental law. It is a document having a special legal sanctity which sets out the
framework and the principal functions of the organs of the government. Constitutional laws are those which
regulate the structure of the principal organs of the government; defines their relationship with the citizens and
determines their functions. Constitution embodies the fundamental law of the land; hence, its interpretation
requires greater care and concern than it is required for other Statutes. However, the general rules adopted for
interpreting a written Constitution is same as for construing other statutes. As is the case with the ordinary
Statutes, the court likewise tries to find out the intention of the framers of the Constitution from the words used
by them.
While interpreting the Constitution the judiciary should keep in mind the following.
 Where more than one interpretation of a Constitutional provision is possible; that interpretation which
would ensure a smooth and harmonious working of the Constitution shall be accepted rather than the one
which might lead to absurdity or give rise to practical inconvenience.
 The Constitution should be interpreted in a broad and liberal manner giving effect to all its parts and the
presumption should be that the framers of the Constitution did not intend to give rise to any conflict or
repugnancy.
 While interpreting the Constitution, a construction most beneficial to the widest possible extend must be
adopted.

For example: In the case of K.K Kochuni v State of Madras & Kerala (1960); the SC observed that in case of an
apparent clash between an Article granting fundamental right and any other article; every attempt should be made
to harmonize them and if that is impossible, then one provision should be allowed to yield to the other. In the
case of M Nagaraj v Union of India (2007); the SC observed that a constitutional provision must be construed not
in a narrow and constricted sense but in a wide and liberal manner so that it can take it account the changing
condition and purposes and remain flexible enough to meet the newly emerging problems and challenges.