Rule of Beneficial Construction

Beneficial construction involves giving the widest meaning possible to the statutes. When there
are two or more possible ways of interpreting a section or a word, the meaning which gives relief
and protects the benefits which are purported to be given by the legislation, should be chosen. A
beneficial statute has to be construed in its correct perspective so as to fructify the legislative
intent. Although beneficial legislation does receive liberal interpretation, the courts try to remain
within the scheme and not extend the benefit to those not covered by the scheme. It is also true
that once the provision envisages the conferment of benefit limited in point of time and subject to
the fulfillment of certain conditions, their non-compliance will have the effect of nullifying the
benefit. There should be due stress and emphasis to Directive Principles of State Policy and any
international convention on the subject.

Beneficial Construction of statutes have enormously played an important role in the development
and beneficial interpretation of socio – economic legislations and have always encouraged the
legislators to make more laws in favor of the backward class of people.

Beneficial Construction in Socio – Economic legislations

Socio-economic legislation which is aimed at social or economic policy changes, the

interpretation should not be narrow. Justice Krishna Iyer in a case relating to agrarian reforms
observed that “the judiciary is not a mere umpire but also an active catalyst in the constitutional
scheme”.

In the case of Sant Ram v Rajinderlal, the Supreme Court said that welfare legislation must be
interpreted in a third World perspective favoring the weaker and poor class. It has also been laid
down in the case of labor legislation that courts should not stick to grammatical constructions but
also have regard to teleological purpose and protective intendment of the legislation.
Interpretation of labor legislations should be done by the courts with more concern with the
colour, the context and the content of the statute rather than its literal import.

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.

Beneficial Construction – A tendency rather than a rule

It is said by Maxwell, that Beneficial Construction is a tendency and not a rule. The reason is that
this principle is based on human tendency to be fair, accommodating, and just. Instead of
restricting the people from getting the benefit of the statute, Court tends to include as many
classes as it can while remaining faithful to the wordings of the statute. For example, in the case
of Alembic Chemical Works v Workman, an industrial tribunal awarded more number of paid
leaves to the workers than what Section 79(1) of Factories Act recommended. This was
challenged by the appellant. SC held that the enactment being welfare legislation for the workers,
it had to be beneficially constructed in the favor of worker and thus, if the words are capable of
two meanings, the one that gives benefit to the workers must be used.

When a statute is meant for the benefit of a specific class, and if a word in the statute is capable
of two meanings, one which would preserve the benefits and one which would not, then the
meaning that would preserve the benefits must be adopted and shall be followed by the court of
law. It is important to note that omissions will not be supplied by the court. Only when multiple
meanings are possible, can the court shall pick the beneficial one. Thus, where the court has to
choose between a wider mean that carries out the objective of the legislature better and a narrow
meaning, then it usually chooses the former meaning carrying out the objective of the legislation.
Similarly, when the language used by the legislature fails to achieve the objective of a statute, an
extended meaning could be given to it to achieve that objective, if the language is fairly
susceptible to the extended meaning.

Limitation on the application of Beneficial Construction

If on the application of the rule of beneficial construction, the court finds that it is doing
complete justice and delivering a fair judgment then there is no question of why should not such
rule is applied? But there are certain restrictions which the court has to take care of which at the
time of application have to be adhered to –

1. Where the courts find that by the application of the rule of beneficial construction, it would be
re legislating a provision of statute either by substituting, adding or altering any provision of the
act.

2. Where any word in a statute confers to a single meaning only. Then the courts should refrain
from applying the rule of benevolent construction to the statute.

3. When there is no ambiguity in a provision of a statute so construed. If the provision is plain,

unambiguous and does not give rise to any doubt, the rule of beneficial construction cannot be
applied.

The courts must be vigilant to ensure that benefits conferred by welfare legislation must not be
defeated by subtle devices. It is duty of the court to get behind the smoke screen and discover the
true state of affairs. It can go behind the form and see the substance of the transaction. The policy
of a democratic Government should run in conjunction with the dynamic interpretation offered
by the courts. The courts exist for the society and in the event the courts feel the requirement in
accordance with principles of justice, equity and good conscience, courts must rise up to the
occasion to do complete justice and meet expectation of the people.