DHARMASHASTRA NATIONAL LAW UNIVERSITY,

Jabalpur (M.P.) 482001

Academic Session (2023-2024)

Interpretation of Statutes

Analysis of Municipal Corporation of Delhi v. Female Workers

(muster Roll) AIR 2000 SC 1274

Submitted by: Submitted to:

Akshay Pal Ms. Swati Parmar

BALLB/015/21 Assistant Professor of Law
Semester 6th
INTRODUCTION
The court interprets legislation enacted by the legislature by the theory of separation of powers. The
Judiciary has established several guidelines, precepts, and techniques to ensure consistency and
authenticity in the interpretation of legislative meaning.

The most basic and widely recognized rule of interpretation is the literal rule, which holds that the
words of a legislation should be interpreted literally. As a result, when a phrase is understood to have
a single meaning, all implications should be applied.

BENEFICIAL INTERPRETATION: MEANING AND SCOPE

K. IYER J said "Recall the face of the poorest and the weakest man whom you may have seen, and
ask yourself, if the step you contemplate is going to be of any use to him”3
In cases when a term or phrase is ambiguous or has several conceivable interpretations, the court must
interpret it broadly and justly, rather than absurdly and restrictively, particularly when it comes to
beneficial legislation. This forms the cornerstone of the beneficial interpretation idea.

As the name implies, beneficiary laws were designed to provide particular individuals or the public
at large privileges, advantages, or entitlements. When a question arises over social welfare and
corrective legislation, it is often settled in favor of the individual for whose benefit the law was passed.
It is recommended to use this kind of construction to clear up any ambiguities that may arise in
beneficial legislation, ensuring that the law's goals and intentions are successfully fulfilled.

When the words of the law are clear and unambiguous, the court cannot ignore the plain meaning
and give any other interpretation even when the latter is more consistent with the object of the
legislation.1 Moreover, courts cannot extend any provision to those whom the legislature did not
contemplate to include.2

1
Id.
2
Dedappa v. National Insurance (2008) 2 SCC 595.
 MUNICIPAL CORPORATION OF DELHI VS FEMALE WORKERS (MUSTER
ROLL3

In this instance, the issue was whether or not female employees hired via the muster roll system
could receive benefits under the 1961 Maternity Benefit Act. The court responded in the
affirmative after taking a helpful and/or purposive stance.

ANALYSIS
Maternity Benefit Act is a “beneficial legislation,” thus it is meant to be generous. Applying the
basic rule of beneficial construction, the provisions of this act must be construed in the widest
possible way whenever there is any ambiguity in its construction. This is exactly what was done
in the Muster Roll case.
Section 3(o) of the Act defines “woman” as "A woman employed for wages in any establishment,
whether directly or through any agency". Furthermore, the Act's Section 5 makes it quite clear that
a working woman who is expecting a child is entitled to maternity benefits.

LORD DENNING opined that, the legislation cannot be drafted with divine precision, hence defects
are meant to be there. In case of such defects, judges ought to apply their judicial mind and look into
the intention of legislature considering not only the language of the statutes but also the social
conditions prevalent at the time of its making and the mischief that it sought to remedy.

B. Shah v. Presiding Officer, Labour Court, Coimbatore & Ors.4 is a historic decision in which the
court construed the word "week" in relation to S. 2 (1), 3 (n), and 4 of the Maternity Benefits Act under
sub-sections (1) and (3) of S. 5. The court decided that, for the purposes of the Act, a "week" would
include Sundays while taking a liberal stance in its construction. As a result, they decided that:

In order for women workers to not only live but also regain their lost energy, take care of their
children, continue to be productive workers, and reach their pre-loss productivity levels, the
Court must establish a benevolent rule of construction. When interpreting sections of beneficial
legislation, like the one under consideration—which is based on Article 42 of the Constitution
and seeks to establish social justice for women working in plantations—this rule would be
applicable.

3
(2017) 4 SCC 498.
4
AIR 1978 SC 12.
This has been reiterated in Dr. Ankita Baidya v. Union of India &Ors5, The Supreme Court said that
"the Maternity Benefit Act's reach and sweep have to be as expansive as possible, rather than limited
by any pedantic considerations of word or phrase, being like a piece of social welfare legislation."

The Maternity Benefit Act does not specifically exclude women working on the muster roster from
receiving benefits under the Act, as the Supreme Court correctly pointed out in the Muster Role case.

The court emphasized that the Act's provisions should be read in conjunction with its Statement of
Objects. The court recognized the difficulties that women encounter before, during, and after
pregnancy and declared that the purpose of the Act is to provide working women with dignified access
to all the facilities so they may enter parenthood with dignity.

CONCLUSION
The Supreme Court has ruled that the usual, grammatical, and natural interpretation of a statute's
language should be used to interpret it. If there are unfavorable effects from such an interpretation,
"the appeal must be to parliament and not to this court." Nonetheless, the common theme in the vast
majority of court declarations has been "justice is above all." Judges used their judicial judgment to
address unfair situations that arose from rigorous interpretation.
Over time, the judiciary has recognized that words in law should be given their ordinary and
grammatical meaning in the first instance.

5
W.P. (C) 8748/2018 & CM APPL.45209/2018.