Rules of Interpretation

Interpretation of Statutes

Rules of Interpretation (with

decided cases).

Table of Contents
S No. Particulars Case Law
1. Introduction.

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2. Literal Rule. CIT v. T. V Sundaram Iyyengar (1975) 101 I.T.R

764 SC.
3. Golden Rule. Workmen Of Dimakuchi Tea Estate vs The
Management Of Dimakuchi tea estate, 1958 AIR
353.
4. Mischief Rule. Bengal Immunity Co. v. State of Bihar (1955)
AIR 1955 SC 661.
5. Harmonious Union of India v. Elphinstone Spinning and
Construction. Weaving Co. Ltd (2001) 4 SCC 139).
6. Ejusdem Generis. Siddeshwari Cotton Mills (P) Ltd v UOI, AIR 1989
SC 1019.
7. Conclusion.

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Introduction
Interpretation of statutes refers to the process of
understanding and giving meaning to the provisions and
provisions of a law or statute. When laws are enacted by
legislatures, they are often written in broad and general
terms, which can lead to different interpretations and
understandings. The role of statutory interpretation is to
clarify the meaning and intention behind the statutory
language.

Rules of interpreting statutes are necessary because laws

must be applied to specific cases and situations. It
involves analysing the text of the statute, considering its
purpose, examining the legislative history and applying
established legal principles and rules of interpretation.
The goal is to determine the legislative intent or the
purpose the lawmakers sought to achieve when enacting
the law.

Courts, judges and legal professionals are primarily

responsible for interpreting statutes when resolving
disputes or applying the law in specific cases. Different
rules of interpretation of Statutes may be employed,
including textualism, which focuses on the plain
meaning of the words in the statute or purposivism,
which emphasises the legislative purpose and intent
behind the law.

The rules of interpretation, particularly within the

context of Indian jurisprudence, are instrumental in
shaping the legal landscape and ensuring justice is

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served. Interpretation involves the meticulous dissection

of statutes, case laws, and legal documents to unearth
their true meaning, thereby ensuring consistency,
fairness, and adherence to the principles of justice. In
this essay, we will explore the essential rules of
interpretation and their practical applications through
Indian case laws, shedding light on how these rules have
evolved and continue to play a vital role in the Indian
legal system.

The rules of interpretation of statutes include the Literal

Rule, the Mischief Rule, the Golden Rule and the Rule of
Harmonious Construction.

Literal Rule

The Literal Rule, which suggests that the words of a

statute should be interpreted in their plain and ordinary
meaning, is a fundamental rule of interpretation.
However, this rule is not without its nuances. The Indian
judiciary has consistently upheld this rule while also
recognizing its limitations.
A classic example can be seen in the case of CIT v. T. V
Sundaram Iyyengar (1975) 101 I.T.R 764 SC. In this
case, the Supreme Court of India upheld the Literal Rule
but emphasized that in cases where adherence to the
literal interpretation leads to absurdity or injustice, the
courts may deviate from it. This case illustrates how the
Literal Rule is a valuable tool in statutory interpretation
while recognizing the need for flexibility when
circumstances warrant it.

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Golden Rule

The Golden Rule, which allows for a departure from the

literal interpretation when the literal interpretation would
lead to an absurd result, has been applied in various
Indian cases. In Workmen Of Dimakuchi Tea Estate vs
The Management Of Dimakuchi tea estate, 1958 AIR
353, the Supreme Court of India employed the Golden
Rule to resolve an issue of interpretation in the context of
the Industrial Disputes Act, 1947. The court held that
the literal interpretation of the provision would lead to an
absurd and unintended consequence, so it applied the
Golden Rule to ensure a just and reasonable
interpretation.

Mischief Rule

The Mischief Rule, also known as the Heydon's Rule, is

applied to discover and remedy the mischief or defect
that the statute in question seeks to address. The rule
was effectively employed in the case of Bengal Immunity
Co. v. State of Bihar (1955) AIR 1955 SC 661. In this
case, the Supreme Court delved into the historical
context and purpose of a constitutional amendment to
interpret and harmonize its provisions. By understanding
the mischief that the amendment aimed to rectify, the
court arrived at a just interpretation.

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Harmonious Construction

Harmonious construction is a principle that suggests

that statutes should be interpreted in a way that
reconciles seemingly conflicting provisions, avoiding any
inconsistency. The case of Union of India v.
Elphinstone Spinning and Weaving Co. Ltd (2001) 4
SCC 139) is a notable example where the Supreme Court
adopted the principle of harmonious construction to
resolve conflicting provisions within the Income Tax Act,
ensuring coherence in the law's application.

Ejusdem Generis

The Ejusdem Generis rule is applied when a general term

follows specific terms in a list, implying that the general
term should be interpreted in the context of the specific
terms. The Supreme Court in Siddeshwari Cotton Mills
(P) Ltd v UOI, AIR 1989 SC 1019, while interpreting the
expression 'any other process' appearing along-with the
words 'bleaching, mercerizing, dyeing, printing, water-
proofing, rubberizing, shrink-proofing, organic
processing in section 2(f) of the Central Excise & Salt Act,
1944 (as it stood prior to its substitution by Central
Excise Tariff Act, 1985) read with Notification No 230 and
231 dated 15th July, 1977 with the aid of the principle of
Ejusdem Generis has said that the foregoing words,
which precede the expression 'or any other process'
contemplate process, which import a change of a lasting
nature must share one or the other of these incidents.

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Conclusion

In the realm of Indian jurisprudence, the rules of

interpretation are indispensable tools for the judiciary in
ensuring the equitable and consistent application of
laws. These rules, including the Literal Rule, Golden
Rule, Mischief Rule, Harmonious Construction, and
Ejusdem Generis, provide a structured framework for
unravelling complex legal provisions and statutes.
Through a careful analysis of case laws, we have seen
how these rules are not just theoretical concepts but
practical instruments for the Indian judiciary. They
enable the courts to interpret statutes in a manner that
upholds the principles of justice, equity, and
reasonableness. As the Indian legal landscape continues
to evolve, the rules of interpretation remain a cornerstone
of jurisprudence, ensuring the rule of law and
safeguarding the rights of citizens.
The rules of interpretation of statutes play a crucial role
in ensuring the effective and consistent application of the
law. The Literal Rule emphasises the plain meaning of
words, while the Mischief Rule aims to discern the
lawmakers’ intent by addressing the gaps in previous
laws. The Golden Rule provides flexibility by allowing
departure from the literal meaning to avoid absurd
outcomes.

Finally, the Rule of Harmonious Construction

harmonises conflicting provisions to give effect to the
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overall purpose of the statute. By employing these rules,

courts strive to uphold the principles of fairness, justice
and the proper functioning of the legal system.

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