INTERPRETATION OF STATUTES PROJECT

NATIONAL LAW UNIVERSITY ODISHA

INTERPRETATION OF STATUTES

“THE ROLE OF PARLIAMENTARY AND LEGISLATIVE HISTORY IN THE

INTERPRETATION OF INDIAN STATUTES”

SUBMITTED TO :

PROF.ABHIK MAJUMDAR

ASSISTANT PROFESSOR OF LAW

NATIONAL LAW UNIVERSITY ODISHA.

SUBMITTED BY:

PURNIMA SRIVASTAVA
(2011/B.A.LL.B /040)
RIYANKA ROY CHOUDHURY
(2011/BBA.LL.B./060)

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TABLE OF CONTENTS

INTRODUCTION ................................................................................................................................ 3

UNDERSTANDING PARLIAMENTARY AND LEGISLATIVE HISTORY ...................................................... 4

Parliamentary history ................................................................................................................. 4

Legislative history ....................................................................................................................... 4

IS LEGISLATIVE HISTORY BINDING .................................................................................................. 4

LEGISLATIVE HISTORY AND LEGISLATIVE INTENTION ...................................................................... 5

REASONS FOR THE COURT'S USAGE OF LEGISLATIVE HISTORY ....................................................... 6

IS LEGISLATIVE HISTORY USAGE MOTIVATED BY DISAGREEMENT AMONG THE JUSTICES.............. 7

THE USE OF PARLIAMENTARY AND LEGISLATIVE HISTORY IN THE INTERPRETATION OF INDIAN

STATUTES :WITH REFERENCE TO CASE LAWS ................................................................................... 8

CONCLUSION .................................................................................................................................. 13

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 INTERPRETATION OF STATUTES PROJECT

“The essence of law lies in the spirit, not its letter, for the letter is significant only as being the
external manifestation of the intention that underlies it” –Salmond

INTRODUCTION

Interpretation is as ancient as language. Highly structured “rules of interpretation” were

developed at a very primitive stage of the Hindu civilization. Interpretation is a knack of finding
out the object of an enactment by construing the words in their natural and ordinary meaning.
The Court is not supposed to interpret arbitrarily and thus certain basic principles have been
evolved. These principles are described as ‘rules of interpretation’. Its object is to ascertain the
intention of the legislature communicated expressly or impliedly in the language used. As stated
by Salmond,
"By interpretation or construction is meant, the process by which the courts seek to ascertain the
meaning of the legislature through the medium of authoritative forms in which it is expressed."
When the words in a statute are unclear. It is the task of the court to interpret it by referring to
internal as well as external aids. Apart from the intrinsic aids such as preamble and the purview
of the act, the court considers resources beyond the act, these are called extrinsic aids. They
mainly deal with the history of the act.
But this Historical setting are not used as an aid if the words are clear, if the wordings are
unclear, the historical setting may be taken into account in order to achieve the proper
construction. Historical setting comprises of parliamentary history, historical facts, statement of
objects and reasons, report of expert committees.1

1
Ca. Rajkumar S. Adukia , Interpretation of Statutes

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UNDERSTANDING PARLIAMENTARY AND LEGISLATIVE HISTORY

Parliamentary history stands for the procedure by which an act is enacted. This contains
conception of an idea, drafting of the bill, the debates, the amendments etc. Speech made during
over of the bill, amendments contemplated during the progress of the bill are considered in
parliamentary history while the papers sited before the cabinet which pronounced for the
introduction of the bill are not germane since these papers are not sited before the parliament.2

Legislative history means -

(i) The legislative antecedents of the statutory provision under consideration ,i.e.
corresponding provisions in previous enactment since repealed and re-enacted with or
without modification3
(ii) Pre parliamentary materials relating to the provision or the statue in which it is
contained ,e.g. reports of committees and commission
(iii) Parliamentary materials

IS LEGISLATIVE HISTORY BINDING

This notion is completely rejected. On contrary, there seems to be broad consent that legislative
history is just a tool with acts as a "guiding function" for the courts. Variation of opinion arises
regarding the relative weight to be provided to the historical interpretative method in relation to
other methods. Advocates of legal discourse theory suggest a ranking that usually places
arguments based on legislative intent higher than others." furthermore, increasing number of
scholars are of the view that while a categorical duty of the courts to stick to legislative history
might not exist, an obligation to refer the materials does .4

2
Justice A.K. Srivastava, Interpretation of Statutes
3
These are not the same thing as statutes in parimateria
4
Kenneth R. Dortzbach, Legislative History: The Philosophies of Justices Scalia and Breyer and the Use of Legislative Historyby
the Wisconsin State Courts Volume 80, Issue 1 2006

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LEGISLATIVE HISTORY AND LEGISLATIVE INTENTION

It is important to differentiate between legislative history and legislative intent.

According to Black's Law Dictionary legislative intent 5 means "the design or plan that the
legislature had at the time of enacting a statute."
It does not essentially reveal the meaning of each word; however it does offer courts with a ways
of selecting between competing interpretations. Few schools of legislative interpretation offer
that the court's obligation is to determine and uphold the intention of the legislature; while some
should the existence of a collective intention and the necessity to determine such, even if it does
exist. For those in the former school, it is one mode to discern legislative intent.

According to Black's Law Dictionary legislative history means

"The back ground and events leading to the enactment of a statute, including hearings
committee reports, and floor debates."6
In the beginning of the definition- "the background and events" is in fact broader than the
general perception of legislative history and, if it were not restricted by the remainder of the
definition, would appear to cover more than the documents drafted during the legislative process.
It includes the "documents [legislatures generate] in the course of enacting statutes.7

5
Black's Law Dictionary, at 919.
6
Black's Law Dictionary, at 919.
7
Stacey l. Gordon and Helia Jazayeri, lost legislative Intent: What will montanans do when the meaning
Isn't plain? mont. L. Rev. 1 2009

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REASONS FOR THE COURT'S USAGE OF LEGISLATIVE HISTORY

Many scholars have tried to understand the motive of judges for citing legislative history.The
usage of legislative history is motivated by a combination of legal and ideological
considerations.
Usually, the legal variables have a considerably greater impact on the possibility of legislative
history use than the ideological variables, but the influence of the ideological variables cannot be
denied. The intricacy of a statute amplifies the likelihood of legislative history usage, while
routinely amended statutes are less prone to obtain such treatment. 8

The age of the statute is also relevant, but its outcome is neither linear nor monotonic: extremely
new and old statutes are less likely to extract legislative history usage than statutes of
intermediate age. The facts also recommend that the usage of legislative history by one justice
induces other justices to respond in the similar kind.

With regard to the effect of ideological factors, liberal justices are usually more likely than
conservative justices to use legislative history. Consequently, the rightward shift in the
ideological composition of the Court has greatly corresponded with a falloff in the overall usage
of legislative history since the mid-1980s.9

8
James J. Brudney &Corey Ditslear, Liberal Justices' reliance on Legislative history: Principle, Strategy, and
The Scalia effect, 29 Berkeley J. Emp. &lab. L. 117 (2008)
9
David s. Law & David Zaring, law versus ideology: The Supreme Court and the Use of legislative history51 Wm. & Mary l.
Rev. 1653 2009-2010

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IS LEGISLATIVE HISTORY USAGE MOTIVATED BY DISAGREEMENT AMONG THE

JUSTICES

There is one question that has to be delving into, to what limit, if any, do the Justices refer to
legislative history in order to retort to the arguments and positions of other Justices?
Difference over the meaning of a statute enhances the usage of legislative history. When Justices
differ on the merits, it is expected from them to resort to legislative history as a way of
strengthening their own arguments, and weakening those of the opponents.

It appears that Court's legislative history opinions yields little aid for this hypothesis. Indeed, the
opposite view can be:
Opinions for a unanimous Court are considerably more likely to refer to legislative history than
other kinds of opinions. However, this finding is deceptive. It is an error to suppose that
unanimity enhances legislative history usage. Most of the majority opinions are unanimous
opinions and majority opinions-unanimous or else-are more likely to refer to legislative history
than are minority opinions.10

10
David s. Law & David Zaring, Law versus Ideology: The Supreme Court and the Use of Legislative history 51 Wm. & Mary l.
Rev. 1653 2009-2010

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THE USE OF PARLIAMENTARY AND LEGISLATIVE HISTORY IN THE

INTERPRETATION OF INDIAN STATUTES: WITH REFERENCE TO CASE LAWS

The parliamentary history may be referred for ascertaining the intention, but not for construction,
is pedantic. In fact all such material out freely to be referred to and it is only by resort to such
material that the object of the legislation and how the legislature intended to achieve that object
by the particular statute can be correctly ascertained by the court 11. The reliance which is placed
on legislative history by the courts in determining an issue can be seen in many case laws.

REFERENCE TO PROCEEDING OF LEGISLATURE WHILE DISCUSSING THE CASE LAWS

In Administrator-General of Bengal v. Premlal Mullick12, the question was whether a Hindu

executor was a “private executor” within the meaning of Section 31 Administrator General’s
Act, 1874. The Privy Council held reversing the High Court, that he was a “private executor”
within the meaning of Section 31 of the Act. Their Lordships observed:
“The two learned Judges, who constituted the majority in the appellate court, although they do
not base their judgement upon them, refer to the proceedings of the legislature which resulted in
the passing of the Act of 1874 as legitimate age to the construction of Section 31. Their
Lordships think it right to expresses their dissent from that proposition. The same reasons which
exclude these considerations when the clauses of an Act of the British Legislature are under
construction are equally cogent in the case of an Indian statute”13.

In A. Thangla Kunju Musaliar v. M. Venkatachalarn Patti.14, the questions were whether Section
5(1) of the Travancore Taxation on Income (Investigation Commission) Act, 1124 (ME) was
discriminatory and whether the Commission had authority to investigate any case suomoto. It
was observed:
The question at once arises as to why it was that the legislative authority took the view that there
were possible cases of tax evasion. It has been said that although the statement of the objects and
reasons appended to a bill is not admissible as an aid to the construction of the Act as passed,
yet, it may be referred to only for the limited purpose of ascertaining the conditions prevailing at
the time which necessitated the making of the law15.

11
Abbe R. Gluck, The States as Laboratories of Statutory Interpretation: Methodological Consensus and the new modified
textualism, 119 Yale l.J. 1750 (2014)
12
(1894-95) 22 IA 107: ILR (1895) 22 Cal 788
13
St. J. Langan, Maxwell on the Interpretation of Statutes (12th ed., 1969)
14
AIR 1956 SC 246: 29 ITR 349
15
Ibid at 3

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In S C. Prashar v. Vasantsen Dwarkadas16, S.K. Das, J. observed: The statement of objects and
moons for introducing a particular piece of legislation cannot be used for interpreting the
legislation if the words used therein are clear enough. But the statement can be referred to for the
purposes ascertaining the circumstances which led to the legislation in order to find out what was
the mischief which the legislation aimed at17.

And Kapur, J. observed:

In construing an enactment and determining its true scope it is permissible to have regard to all
such factors as can legitimately be taken into account to ascertain the intention of the legislature
such as the history of the Act, the reason which led to its being passed, the mischief which had to
be cured as well as Site cure as also the other provisions of the statute. This is the rule in Heydon
case". Taking this principle into account it appears that the object of the amendment was to
validate certain notices after the 1959 amendment and after the lapse of eight years from the end
of the assessment year and also to nullify the effect of the Calcutta judgment in Debi Dutta
Moody case.

In Balchand Jain v. State of M.P18. for holding that an order for anticipatory bail could be issued
under Section 438, Criminal Procedure Code, 1973, to a person apprehending arrest under Rule
184 of the Defence and Internal Security of India Rules, 1971, the Court relied on the legislative
history of the provision and on the recommendations of the Law Commission and observations
in the Law Commission Report.

In Emperor v. Benoari Lal Sarma19, Rownand, J. observed:

Sen, J. ,has said in his judgement that it is not open to us to take into account historical facts or
any extraneous evidence either as to whether an emergency existed or whether the Governor
General had judged an emergency to have arisen.
But according to Lord Halsbury in Powell v. Kempton Park Racecourse Co., such topics as the
history of legislation and the facts which give rise to the enactment may usefully be employed to
interpret the meaning of the statute, though they do not afford conclusive argument20.

In State of Travancore-Cochin v. Bombay Co. Ltd21, the respondents claimed exemption from
sales tax on the ground that their commodities to foreign buyers in CIF or FOB contracts were
sales "in the course of export of the goods out of the territory of India” within the meaning of
Article 2860)(b) of the Constitution. The High Court held in favour of the respondents. The

16
AIR 1963 SC 1356: (1964) 1 SCR 29
17
S.G.G. Edgar, Craies on Statute Law (1999)
18
(1976) 4 SCC 572 :1976 SCC (CRI) 689
19
AIR 1943 FC 36: 1943 FCR 96: (1943) 2 MAD LJ 207.
20
Vepa P. Sarathi, Interpretation of Statutes (4th ed., 2003)
21
AIR 1952 SC 366: 1952 SCR 1112

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Supreme Court confirmed the Judgment, but observed:

The use made by the learned Judges below of the speeches made by the members of the
Constituent Assembly in the course of the debates on the Draft Constitution is unwarranted. That
this form of extrinsic aid to the interpretation of statutes is not admissible has been generally
accepted in England, and the same rule has been observed in the construction of Indian statutes.
The reason behind the rule was explained by one of us in A.K. Gopalan v. State of Madras22.;
thus:
'A speech made in the course of the debate on a Bill would at best be indicative of the subjective
intent of the speak, but it could not reflect the inarticulate mental process lying behind the
majority vote which carried the Bill. Nor is it reasonable to assume that the minds of all the
legislators were in accord'23;
or as it is more tersely put in United States v. Trans-Missouri Freight Assn24.
'Those who did not speak may not have agreed with those who did; and those who spoke might
differ from each other.' The rule of exclusion has not always been adhered to in America, and
sometimes distinction is made between using such material to ascertain the purpose of a statute
and using it for ascertaining its meaning. It would seem that the rule is adopted in Canada and
Australia.

In State of Bihar v. Khas Karanpura Collieries Ltd 25 , while holding that Section 30-A was
inserted retrospectively by Act 15 of 1958 in the Mines and Minerals (Regulation and
Development) Act, 1957 and that it gave temporary immunity front the applicability of Sections
9(0 and 16(1) of the Act to statutory mining leases until the Central Government by notification
made the provisions applicable with or without modification to such leases, the Court observed:
There can be no room for doubt that the legislature intended that Section 30-A of the 1957 Act
should cover the aforesaid statutory leases as well. It will be apposite in this connection to refer
to the statement of objects and reasons given in the Bill which sought to introduce Section 30-A
in the 1957 Act with retrospective effect which can be usefully resorted to for ascertaining the
true scope of the section and the extent of the protection afforded by it.

The Explanatory Memorandum attached to the Rules, is in the nature of Statement of Objects
and Reasons, and may be referred to P.S. Mahal v. Union of India26:
The aids which Parliament availed of such as the report of a special committee preceding the
enactment, existing state of the law, the environment necessitating the enactment of the
legislation, and the object sought to be achieved, are useful for deciphering the real intention of
the Parliament and therefore cannot be denied to the court.
Therefore, reports of the committee which preceded the enactment of legislation, reports of joint
22
AIR 1950 SC 27: (1950) 51 CRI LJ 1383
23
G.P. Singh, Principles Of Statutory Interpretation (11th Ed., 2008)
24
169 US 290 (1897).
25
(1976) 4 SCC 134
26
(1984) 4 SCC 545: 1985 SCC (L&S) 61

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parliamentary committees, report of a commission set up for collecting information leading to

the enactment are permissible external aids to construction."
Report of joint Select Committee on Bill to amend the Act was referred to see the object and
purpose.
In Narain Khamman V. Parduman Kumar Jain27., it was held that:
Though the Statement of Objects and Reasons accompanying a legislative Bill cannot be used to
determine the true meaning and effect of the substantive provisions of a statute, it is permissible
to refer to the Statement of Objects and Reasons accompanying a Bill for the purpose of
understanding the background, the antecedent state of affairs, the surrounding circumstances in
relation to the statute, and the evil which the statute sought to remedy.

In Union of India v. Tulsiram Patel, it was held: Support to the conclusion that provision wholly
excluded natural justice rules sought from factors such as existence of provision in the
Constitution since inception, its conscious introduction after considerable debate and deliberation
and democratic ideology of the members of the Constituent Assembly.

In Bachan Singh v. State of Punjab, it was held: Constitutional law raises, in a legal context,
problems of economic, social, moral and political theory and practice to which non-lawyers have
much to contribute. When judges are confronted by issues to which there is no legal answer,
there is no reason (other than a desire to maintain a fiction that the law pros-ides the answer) for
judicial discretion to be exercised in a vacuum, immune from non-legal learning and extra-legal
dispute. The judges must also consider while deciding an issue of constitutional adjudication as
to what would be the moral, social and economic consequences of a decision either way.

In Special Reference No. z of 2002, Re, (Gujarat Assembly Election matter)28the debates in the
Constituent Assembly on Articles 85 and 174 was looked into. Khare, J. (as the learned Chief
Justice then was) referred to Kesavananda Bharti cases29 in support of the proposition that the
Constituent Assembly Debates are permissible aids in construction to ascertain the intention of
the Constitution. The learned Judge observed as follows. One of the known methods to discern
the intention behind enacting a provision of the Constitution and also to interpret the same is to
look into the historical legislative developments, Constituent Assembly al provision. Debates or
any enactment preceding the enactment of the constitution.

In Kesavananda Bharti v. State of Kerala 30 , it was held that Constituent Assembly Debates
although not conclusive, yet show the intention of the framers of the Constitution enacting
provisions of the Constitution and the Constituent Assembly Debates can throw light in
ascertaining the intention behind such provisions. Reference to Constituent Assembly Debates in

27
(1985) 1 SCC 1
28
(2002) 8 SCC 237 AT P. 265
29
(1973) 4 SCC 225: AIR 1973 SC 1461
30
(1973) 4 SCC 225: AIR 1973 SC 1461

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interpreting a Constitutional provision: In Kesavananda Bharti v. State of Kerala, H.R. Khanna,

J. observed that the speeches in the Constituent Assembly can be referred to for ascertaining the
history of the constitutional provision.

In Fagu Shaw v. State of W.B 31 Bhagwati, J. observed: It was at one time thought that the
speeches made by the members of the Constituent Assembly in the course of the debates on the
Draft Constitution were wholly inadmissible as extraneous aids to the interpretation of a
constitutional provision, but of late there has been a shift in this position and following the recent
trends in juristic thought in some of the Western Countries and the United State, the rule of
exclusion rigidly followed in Anglo-American jurisprudence has been considerably diluted.

In Ashoka Kumar Thakur v. Union of India32, while justifying the separate treatment given to
minority institutions on the basis of constitutional provision the Court observed that it is a settled
position that in statutory interpretation external aids have only a limited use. [I respectfully
submit that all aids external and internal are for the purpose of finding out the object of a
statutory provision or a word or phrase and that interpretation is on the basis that it achieves that
object and fits the context.] The only comment I have to make is, instead of looking for the
object if there is a doubt, it is better to start with the object, because, I respectfully submit it will
lead to greater certainty, shorter judgments and no dissents. The difference between
consolidation and codification is that in the latter both statutes and case law are integrated and
enacted as a whole after the necessary dovetailing, reconciliation and distillation33.

31
(1974) 4 SCC 152: 1974 SCC (CRI) 316
32
(2008) 6 SCC 1
33
Vepa P. Sarathi, Interpretation Of Statutes (4th Ed., 2003)

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CONCLUSION

The conception that the legislative history must be sternly adhered to barely has any advocates
now a days. It is just a tool and "aid" or "guide" as stated in Pepper v. Hart 34 -“To better
understand ambiguous provisions”.
Now the discussion has thus swung towards ascertaining the significance given to it. There exist
no universal rules on the interpretation of legislative. It is, though, a worthwhile duty for legal
academics to examine the possibilities and confines of a hierarchical order of different legislative
materials, ranging from preparatory reports by expert panels to commentary by the Ministry.
Besides, judges and legal scholars should observe the detail process of how statutes are made in
order to be in a better position to consider their value.35
So far as the Indian judiciary is concerned they have tried to clear the poison of these external
sources by way of verdicts.
Debates have been referred many a time by the court in order to reach a conclusion in a case.
Recently SC has cleared that in S.R. Chaudhuri v. St. of Punjab36
“That it is a settled position that debates in the Constituent Assembly may be relied upon as an
aid to interpret a Constitutional provision because it is the function of the Court to find out the
intention of the framers of the Constitution.”
But on speeches in K.S. Paripoornan v State of Kerala and 37others while making a distinction
between speeches of the mover and that of the other members, they held-
“Speeches made by the Members of the Parliament at the time of consideration of a Bill, it has
been held that they are not admissible as extrinsic aids to the interpretation of the statutory
provision. However, speeches made by the mover of the Bill or Minister may be referred to for
the purpose of finding out the object intended to be achieved by the Bill”
Regarding Law Commission’s Report it was held that, “It can also be referred to where a
particular enactment or amendment is the result of recommendations of Law Commission
Report.”

34
[1993] AC 593
35
Holger Fleischer, Comparative approaches to the use of Legislative History in Statutory Interpretation, 60 am. J.
Comp. L. 401 2012
36 (2001) 7 SCC 126
37 AIR 1995 SC 1012

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This judgment was further validated by The Supreme Court in Rosy and another v State of
Kerala and others 38 , where they considered Law Commission of India, 41st Report for
interpretation of section 200 (2) of the Code of Criminal Procedure, 1898.
Finally as far as Statement of Objects and Reasons, accompanying a legislative bill is concerned;
court has cleared that in Devadoss v. Veera Makali Amman Koil Athalur39
“It is permissible to refer to it for understanding the background, the antecedent state of affairs,
the surrounding circumstances in relation to the statute and the evil which the statute sought to
remedy. But, it cannot be used to ascertain the true meaning and effect of the substantive
provision of the statute.” Thus it has been understood that there has been quite a bit ambiguity in
interpretation of statutes through legislature history. Hence it needs to be adhered to and intent of
the parliamentarian is of the prime importance for understanding the intent of the legislature in
the framework of the statutes.

38
(2000) 2 SCC 230
39
AIR 1998 SC 750

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BIBLIOGRAPHY

Statutes Referred
 Constitution of India, 1949
 Mines and Minerals (Regulation and Development) Act, 1957
 Criminal Procedure Code, 1973
 Travancore Taxation on Income (Investigation Commission) Act, 1124
 Administrator General’s Act, 1874

Books Referred
 St. J. Langan, Maxwell on the Interpretation of Statutes (12th ed., 1969)
 Vepa P. Sarathi, Interpretation of Statutes (4th ed., 2003)
 G.P. Singh, Principles Of Statutory Interpretation (11th Ed., 2008)

Articles Referred

 Kenneth R. Dortzbach, Legislative History: The Philosophies of Justices Scalia and

Breyer and the Use of Legislative History Volume 80, Issue 1 2006
 Stacey l. Gordon and HeliaJazayeri,lost legislative Intent: What will montanans do when
the meaning Isn't plain? Mont. L. Rev. 1 2009
 James J. Brudney&Corey Ditslear, Liberal Justices' reliance on Legislative history:
Principle, Strategy, and the Scalia effect, Berkeley J. Emp. &lab. L. 117 (2008)
 David s. Law & David Zaring, law versus ideology: The Supreme Court and the Use of
legislative history51 Wm. & Mary l. Rev. 1653 2009-2010
 Abbe R. Gluck, The States as Laboratories of Statutory Interpretation: Methodological
Consensus and the new modified textualism, 119 Yale l.J. 1750 (2014)
 Holger Fleischer, Comparative approaches to the use of Legislative History in Statutory
Interpretation, 60 am. J. Comp. L. 401 2012

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Internet Sources
 http://www.jstor.org/stable/10.2307/23251934?Search=yes&resultItemClick=true&searc
hText=The&searchText=role&searchText=of&searchText=parliamentary&Statutes
 http://ijtr.nic.in/articles/art21.pdf
 http://www.lawyersclubindia.com/articles/Interpretation-of-Statute5430.aUwTmSwSN
 http://www.nhs.vic.edu.au/library/legaldate/LegalDate_Vol_19_No_2_May_2007.pdf
 http://caaa.in/Image/Interpretation%20of%20Statutes.pdf

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