Avinash Alladi's IOS Notes

20161482 Interpretation of Statutes Avinash Alladi
Interpretation of Statutes – Notes
Introduction
Philosophical arguments – see why we need rationalized judgment?

Hart – core area is precise and thus sticks to the law.
Penumbra – vague, judge had discretion to decide these cases as they see fit.
Dworkin – no discretion is awarded to the judge, unless the law provides for it. But
there are principles, which even if they are not stated, must be read in. So, a judge
cant use discretion, but can use principles. This is because principles don’t change.
Underlying morality in law – connection in law that forms inner morality.
Why are reasoned judgments important?

Example, no vehicles allowed in the park
What is a vehicle?
Look at the purpose of the Rule.
The law should not cover incidents that it doesn’t wish to cover. But it should be
general enough to encompass a large body of scenarios without having to list out each
one of it.
No law is without exceptions
Law is facile, designs with no straight lines and always exceptions exist.
It is very difficult to find a perfectly appropriate law.
Example, someone who wants to evade taxes, the tax laws become road maps of what
not to do.
When it comes to interpreting these laws and maintaining integrity, we want the law
to merit/help those who can claim the exceptions and use it for their advantage. Thus,
we can make laws specific but it will still be difficult to read the law. Therefore, it
can’t be a perfectly general and applicable law.
Case Law – Riggs v. Palmer

Facts - The def killed his grandfather because his grandfather remarried and there was
a possibility of him changing his will. The def was tried and convicted for murder.
Issue - What about inheritance?

Law of wills says nothing about inheriting from a person who you’ve killed.
Judge Grey – If this man isn’t allowed to inherit, then he faces additional punishment
than what the law prescribes i.e., ex-post facto law.
In criminal cases, there can be no ex-post facto laws. It cannot make it applicable with
a retrospective effect. But, tax laws are exceptions.
Majority opinion – when legislators are making laws, they are aware of principles of
natural justice. One cannot take advantage of his wrong. Legislators adhere to
underlying principles unless specifically excluded, the principle will be read into the
law.
Held – The defendant is not allowed to inherit his grandfather’s property.
Case Law – Snail Darter
Facts – Construction of dams in Tennessee valley. Authorities were trying to do the
construction and the conservationists were trying to stop it. US Congress passed a law
that allowed for the stopping of projects in case it was likely to threaten an
endangered species.
Conservationists found snail darter that was an endangered species likely to be driven
out by the construction of the dams. Now the dams were almost completed and a lot
of money had been invested into it.
Court stated that endangered species were present. Therefore, stopping was within the
law.
What did the law mean? Projects at the beginning stage, yet to be started or
completed?
Disagreements about the law
 Empirical – questioning the existence of the law itself.
 Theoretical – questioning the meaning of the law. It may mean completely
different from the text.
 Factual – disagreement about the facts. Example – is snail darter an endangered
species or not?
Case Law – Plessey v. Ferguson

Facts – Person was 1/8th black who sat in a coach reserved only for white people.
When asked to step down, he claimed it was violative of his right to equality.
Ruling – The Court held that ‘separate but equal’ is not violation of right to equality.
There was same number of carriages for both black and white people. White people
were also not allowed to enter into carriages reserved for black people.
Case Law – Brown v. Board of Education

There were separate schools for black and white people. This Separate but equal in
education was challenged in courts. By separating schools, adequate quality of
education is not being provided.
This case does not overrule the ‘separate but equal’ interpretation but was just said
that this distinction does not apply to education.
Antonin Scalia v. Stephen Breyer on the Constitution debate

Antonin Scalia was an originalist. He emphasized on application of literal rule, judges
cannot interpret the law, as they want to. The only interpretation should be with
respect to how the makers construed it to be at the same time of making it.
What is the role of the judge?

- Judges are not here to make the law but they are here to interpret and apply the
law. However, there is no clarity as to what exactly law is.
- If one subscribes to natural law theory, then they are going above law and into
morality.
- However there is no solid understanding as to what is law because there are
sufficient theories of law to confuse law.
- So technically Scalia interprets the law by using his mind in interpreting it.
Therefore values affected decisions are given.
- Objectivity is not value neutral. Scalia doesn’t acknowledge that his
objectivity is inherently biased. Therefore this is not value neutral enough.
Therefore it is how we critique the idea of objectivity.
Chain Novel Theory

- Dworkin’s idea where he speaks of law as integrity.
- Law is a continuing chain that is coherent. While interpreting the law, you
give legislature the best possible meaning given the legal history with which it
came up.
- Dworkin said that interpretation of law is extremely similar to the
interpretation of the work of art.
- Public v. private – law is for the public but it affects people only privately. So
only the ones getting affected by law are ones who care about art because it is
for the public.
- Law is a self-serving idea assumed to affect everyone.
- There is enough scope in law to make exaggerated reading. So, we have
dissent and majority opinions.
- Justice is open to interpretation, just like art.
- Point of law is how we can interpret it. Find the best possible meaning of the
law in context of the legislature/statute, says Dworkin.
- Chain Novel: A writes the 1 st chapter, B writes the 2 nd chapter, C writes the 3 rd
chapter and so on. B can’t scratch the idea of A, he will have to continue it.
- Chain novel in law: Lawyers and judges have to continue process of chain
novel and give it the best interpretation in context of history with precedents
and statutes.
- Dworkin said there is an underlying idea of true law and the judge’s role is to
identify it.
- Dworkin says that judges must pick that interpretation that most advances the
ideas of justice given the history of the legal system.
- There are principles in every system. They are the foundation of the system.
Role of the judge is to give best possible interpretation that advances the idea
of justice seeing history.
Rule Skepticism and Speluncean Explorers
- Rule skepticism – legal realism movement.

- Legal realism – what is the reality of how law works?
- More important is to study the decisions of a judge to predict the outcome of a
present case.
- Studying the law is just a sanction.
- Legal realists always look at what the judges and courts have done previously.
(What judges do?)
- Rules skeptics are saying that there is nothing as a good rule. They are critical
of rules providing guidelines.
- Whether rules exist or not, doesn’t matter much as people aren’t deterred from
doing anything.
- Rule skeptics say that bad man will get away with anything he wants to do.
- It depends on how the rules are imposed and the stringency in rules.
- Judges try to justify their decisions because there are rules. Example – trying
to put the cart before the horse is wrong whereas trying to put the horse before
the cart makes sense because the horse pulls the cart and not push the cart.
Speluncean Explorers
Eskridge’s Theory of Practical Reasoning
- Speaks about textualism and chain novel theory.

- Criticizes absolutist theory of interpretation that says to apply the text
absolutely.
- Absolutist theories are of 3 types
 Intentional – intent of the legislature at the time of drafting.
 Purposive – the purpose of the statute.
 Textual – the text of the statute.
- The difference between the 3 is that the questions in intentional what was the
individual legislators thinking for instance we talking about Ambedkar’s
intentions.
- Purposive is slightly more contextual. We look at what are statutes supposed
to do.
- Textual has 2 types, strict textualism and loose textualism.
- Absolutist theories are generally not a good idea because it becomes an ad-
hoc decision in each case. We don’t end up looking at the context of each
case, which is different.
- Eskridge proposes the funnel of abstraction instead.
-
-
Most Abstract
Current Policy
Evolution of Statute
Legislative purpose
Specific + General legislative history
Statutory text
Least abstract
- This is not a hierarchy as proposed by Eskridge. However, practically, this is how a

statute is looked at.
- Example – current policy will have the largest number of considerations and
numbers to look at.
- It is not necessary that the judge will look into all these aspects.
- Contextualize how interpretation is happening within each particular case.
- Since there is no clear-cut hierarchy, it is less absolutist that all of these.
- Therefore theory is one of practicality.
- Judges make use their discretion and they have to take care to take into
consideration of all the texts. Thus, flexibility is allowed.
Case Law – United Steelworks v. Weber (1979)

Factual Issue: The question was with respect to affirmative action.
The constitution of USA doesnot allow for it. It is more stringent than India. Mostly
found in the Civil Rights Act.
Section 703(a)(i) of the Act – it is unlawful to discriminate on the basis of race,
religion, sex, etc. they used the formal equality theory.
Issue: Does this allow for positive discrimination?
Section 703(j) – nothing in this section shall be interpreted as to require any employer
to give special treatment to anyone on account of de-facto racial imbalance in the
employer’s workforce.
The Civil Rights Act does not define what discrimination is.
United Steelworks had a training programme, which admitted people in the ratio of
1:1 based on race. For each white, a black had to be admitted. Weber applied for this
work, but didn’t get admission.
Issue: Is this policy violative of the non-discrimination clause?
Ruling: The Court ruled that this is not discrimination because:
 White people are being hired along with black people.
 There is an end goal for this policy.
 Either such policies should time-bound or there must an end goal.
According to Eskridge, the judgment falls more under the funnel of abstraction.
In USA, there are no quotas allowed for black people. Instead they have quotas for
schools instead of races. This is a smart way because of the history of segregation.
Case Law – Griffin v. Oceanic Constructors

Facts: Appellant was injured during his employment and subsequently discharged. A
few weeks later he was again employed. The respondents from his previous
employment withheld $412. Every master or owner who refuses or neglects to make
payment in the manner without sufficient cause shall pay to the employee a sum equal
to 2 days pay for each and everyday during which the payment was delayed. This is
beyond the actual pay of the employee.
This case goes to the court based on this law.
Issue: The question is whether the days are counted till he is hired again or till the
payment is made?
The difference in this case was $6881 v. $302790 stating that the text of the statute is
clear, mentioning that till the payment is made.
Case Law – Bob Jones University v. USA
Facts: University is a non-profit private university. It prescribes a racially
discriminatory admission policy where only white people are admitted.
Section 501(c)(iii) of the Internal Revenue Code provided an exemption on tax for
religious, charitable or educational institutions.
Issue: Whether Bob Jones qualifies for this exemption?
Ruling: SCOTUS unanimously decided that there should be no exemption because it
was for those institutions that are contributing towards welfare of the society. They
looked at the specific and general legislative history although it goes directly against
statutory text.
Eskridge says that courts often use the funnel to justify their actions rather than
absolutism.
Rules of Interpretation
A. Preliminary Rules
1. Literal Rule
 Law literally interpreted. Common understanding of words of the provision.
 Depends on each judge’s understanding of common usage. Not very well
defined.
 Looks at the statute as a whole.
 The natural and ordinary meaning of the word should not be departed from
unless it is shown that the context requires it.
 The context can require it in 2 ways:
 If it results in a contradiction in the statute.
 Absurdity.
 If the statute relates to a specific trade, the usage in that trade will override the
common meaning. Example – practice in law.
 The ordinary sense of a term does not normally refer to the technical sense.
Example – computer.
 If there is a known legal sense of a term, that legal sense will override the
ordinary term. Example – damages, admission, etc.
 First rule to be applied to any statute.
 Can only deviate if the exceptions are justified.
Case Law – B.N.Mutto v. T.K.Nandi

Related to eviction from government services. The govt passed an ordinance directing
govt servants who lived in a govt property in Delhi but also owned another house in
Delhi, and then you must vacate it. Passed on 9 th September 1993 to come into force
within 3 months.
On 30th November 1993, a govt servant retired and was served a notice to evacuate
after the ordinance came into force.
A separate rule was created stating that where a landlord who being a person in
occupation of any residential premises allotted to him by the central government or
any local authority is required by and in pursuance of any general or special order
made by that government or authority to vacate such residential accommodation, there
shall accrue on and from the date of such order to such landlord notwithstanding
anything contained in this act or any other law for the time being in force or in any
contract, whether express or implied, custom or usage to the contrary.
A right to recover immediately possession of any premises let out by him.
A notice was served to the plaintiff on December 11 th 1993. He asks the tenant to
vacate the house.
Has the plaintiff ceased to be a govt employee since he has retired?
Ruling - ……
Case Law – Ramawatar v. Assistant Sale Tax Officer

Question with respect to betel leaves.
Sales Tax Act – section 6 said no taxes on items mentioned in schedule.
Schedule mentions betel leaves as item no. 36 and vegetables except when sold in
sealed boxes (item no. 6). Item 36 was removed from the list.
Appellant claimed that betel leaves are anyway included in item no. 6.
Ruling: Court cited Santra market case. They said vegetables are to be understood as
commonly used ones. They are basically those, which are grown in the kitchen garden
and served on the table. Not a vegetable.
Case Law – Moti v. State of Bihar

Issue: Is sugarcane a green vegetable? Green vegetables are exempted under the Bihar
Sales Tax Act.
Ruling: Sugarcane is not a green vegetable for the same reasons.
Case Law – State of West Bengal v. Washi Ahmed

Issue: Whether green ginger falls in the category of goods described as green
vegetables commonly known as sabzi, tarkari or raag?
Ruling: It is a vegetable.
2. Golden Rule
 Extension of the literal rule of interpretation.
 The literal meaning of the statute should not be departed from unless the result
of the literal rule results in absurdity.
 The parliament must be assumed to have intended whatever the statute says.
 Only in cases of patent absurdity, depart from the literal meaning.
Case Law – Narayan Swami v. Paneerselvam

Issue: Related to the qualification for being elected into the legislative assembly.
Section 5 and 6 of the Representation of People’s Act and Article 171 of the
Constitution of India was the underlying rule of law to be decided upon.
Question related to the appellant’s election under Art 171(3)(b). The appellant was
not a graduate still qualified to be elected?
As per Art 171(3)(b), people voting (electors) should be graduates. No qualification
mentioned for the candidate.
Section 6 of the Act, no such qualification for a candidate. To be eligible to be
elected, one must be an elector as per section 6 of the Act.
The omission u/s 6 seems to be intentional on the part of the Parliament. Had the
legislature wanted the candidate to be a member of the electorate? Patent absurdity
was argued but was rejected by the court and literal rule was applied.
Case Law – S.R.Batra v. Tarana Batra

Facts: Domestic dispute between husband and wife. They were married for a while
and live in the husband’s mother’s house. After a while a dispute arose and wife
leaves for her parental house. Some time later husband files for divorce. Wife comes
back to try again. Finds the door locked. Husband has moved out prior to filing for
divorce.
Issue: Can the wife claim a right to live in that house?
Section 17+19(b) of Domestic Violence Act and shared household defined u/s 2(s) of
the DV Act.
Ruling: the mother in law’s house cant be counted as a shared household as husband
did not have any right or interest in that property. Wife also has no right to live in the
disputed house. The court ruled this as a patent absurdity.
3. Mischief Rule
 Subset of purposive rule of interpretation.
 Can go if literal rule cannot be applied, which cant be addressed by the golden
rule, then one may use the purposive interpretation in the form of mischief
rule.
 4 questions to be answered under this:
 What was the law before the making of the particular Act?
 What was the mischief or defect not provided for?
 What was the remedy the legislature used to cure this defect or mischief?
 What was the reason for the remedy?
Case Law – Hayden’s (1584)

Issue: Whether a lease granted to Hayden was valid?
Ruling: There were copyholds (a type of lease, usually granted for life) in those times.
It was granted to a person W and his sons for life for both W and his son. Later the
lease was granted to Hayden (a normal lease). Within a year an Act comes out
attaching all these lands to the king. It also said that all the leases shall be negated
granted within a year of passing of this Act. The Lords owned these lands and were
benefitting from this Act.
Case Law – RMD Chamarbaugwala v. UOI

The newspaper crossword case with respect to territorial nexus where the crossword
competition, number prizes, picture prizes etc. for which the Solution is prepared
before hand and the winner is chosen by lot.
B. Subsidiary Rules of Interpretation

 All subject to the first 3 main rules of interpretation.
 Statute must be read as a whole and cannot be read in isolation from the rest of
the statute.
 Intention of the legislature has to be gathered from the whole statute. Every part
of the statute must be compared with other parts of the statute.
Case Law – Regional PF Commissioner v. Shree Krishna Metal
Issue: Whether the Company fell under the Employees PF Act of 1952?
Rule: Section 1(3)(a) of the Act states that the Act applies to all factories engaged in
any industry specified in schedule I in which 50 or more persons are employed.
Facts: The Claim by the Company was that it had 3 separate factories in the same
compound containing of a milling paddy, a flourmill and sawmill. None of these
sections employs more than 50 employees individually. Factory has to be an industry
that has 50 employees.
The Claim of the commissioner was that the factory should be specified in schedule-I
and the industry should have 50 people employed.
Issue: Whether the 50 or more people condition applies to factory or industry?
Held: Since the establishment and factory are used in the same sentence and a factory
doesn’t have just 1 building, the phrase applies to a factory.
(i) Rule of Harmonious Construction

 Primarily dealing with constitutional interpretation.
 One will only override the other provision if it cannot be harmoniously
constructed.
(ii) Ut Res Magis Valeat Quam Pereat

 Words must be construed to give a sensible meaning to them.
Case Law – Avtar Singh v. State of Punjab

Section 39 of Indian Electricity Act – whosoever dishonestly abstracts, consumes or
uses any energy shall be deemed to have committed theft within the meaning of the
Indian Penal Code.
Section 50 provides that no prosecution shall be instituted against any person for any
offence against the Act except at the instance of the government or an electrical
inspector or of a person aggrieved by the same.
Avtar Singh has dishonestly abstracted energy. Is it an offence under the Act or IPC?
Since it is an offence under the Act and it is not properly instituted.
Held: The conviction of the appellant must be set aside. The dishonest abstraction of
electricity mentioned in s. 39 of the Act cannot be an offence under the Indian Penal
Code for under it alone it is not an offence; the dishonest abstraction is by that section
made a theft within the meaning of the Code, that is, an offence of the variety
described in the Code as theft. The offence is created by raising a fiction. The section,
which raises the fiction namely s. 39 must be said to create the offence. Since the
abstraction is to be deemed to be an offence under the Code, the fiction must be
followed to the end and the offence so created would entail the punishment mentioned
in the Code for that offence. The punishment is not under the Code itself for under it
abstraction of energy is not an offence at all. Further, the object of s. 50 of the Act is
to prevent prosecution for offences against the Act being instituted by any one who
chooses to do so because, the offences can only be proved by men possessing special
qualifications, and there is no reason why it should not have been intended to apply to
dishonest abstraction of energy made an offence of theft by s. 39.
(iii) Expressio Unius Est Exclusio Alterius

 The express inclusion of one thing is the exclusion of another.
 If a statute includes a particular item without mentioning others, it expressly
excludes those that are not mentioned.
Case Law – Khemka & Co. v. State of Maharashtra

Rule: Central Sales Tax Act’s Section 9(2) – The authority empowered to assess,
reassess, collect and enforce payment of any tax under the general sales tax law of the
appropriate state shall on behalf of the government of India assess, reassess, collect
and enforce payment of tax including any penalty payable by a dealer under this Act
as if the tax or penalty payable by such a dealer under this Act is a tax or penalty
payable under the general sales tax law of the state.
Facts: Basically the state will collect the tax on behalf of the government of India. The
procedure will be the same as what the State Act gives.
Maharashtra Sales Tax Act included some penalties payable for default of tax
payment. Authorities are collecting central taxes and they impose penalties as given in
Maharashtra Sales Tax Act for Central Sales Tax (CST) default against Khemka.
Issue: Can the authority impose penalties as given under the Maharashtra Sales Tax
Act on default of CST?
Held: The manner of collection is discussed in the statute and not what is being
collected. Tax or penalty included under this Act. Therefore it excludes General Sales
Tax Act.
(iv) Noscitur A Sociis

 The meaning of a doubtful word may be ascertained by referring to the
meaning of the words associated with it.
 If a word is not clearly defined, then look at the nearby words.
Case Law – Commissioner of customs and excise v. Savoy Hotels

Issue: Whether Savoy can be taxed for freshly squeezed orange juice that they serve
to their patrons?
Held: Section 35 of Purchase Tax Act – (a) manufactured beverages include fruit
juices and bottled water and syrups, concentrates, essences, powders, crystal or other
products for the preparation of beverages; (b) containers of gas for the preparation of
carbonated beverages.
The items mentioned here are those that are to be pushed through some form of
processing and freshly squeezed orange juice doesn’t qualify.
Case Law – Director of Publication Pros v. Jordan

Facts: Jordan is being charge under the Obscene Publication Act, 1959. Jordan is the
proprietor of a bookshop where a pornographic book was published and sold.
Exception to prohibition: person will not be convicted if it is proved that publication
of the article in question is justified as being for the public good on the ground that it
is in the interest of science, literature, art or learning or of other objects of general
concern. (Does it qualify as an exception under the Act.)?
The claim was that it is an object of general concern for public good of the people.
Example – the book was for unsatisfied homosexuals and heterosexuals.
(v) Ejusdem Generis
 Enumeration of different subjects in an Act, general words following specific
words may be construed with reference to antecedent matters and construction
may be narrowed down by treating them as applying to things of the same
kind as those previously mentioned unless something shows contrary
intention.
 If particular words exhaust the whole genes the general words are constructed
as embracing a larger genes.
Case Law – Siddheswari Cotton Mills v. UOI

Imposition of tax by excise and salt tax where unprocessed cotton fabric is exempted
but a tax is imposed if it has been subjected to processing. This includes bleaching,
mercerizing, dying, printing, waterproofing, rubberizing or any other processes.
Cotton mill sold although it was unprocessed cotton but passed the cotton through
rollers to remove creases. So, basically they were ironing it.
Case Law – Attorney General v. Brown

An ordinance was passed under the prohibition of import proclamation by the king.
Section 43 allowed the crown to pass any proclamation prohibiting the importation of
arms, ammunition, gunpowder or any other goods. Prohibited the importation into UK
to all chemical industries of all description unless under a license.
Pyro Gallic acid was imported without license is used in photography were
confiscated for violation of proclamation.
AG made two claims: ‘Other goods’ including anything; photography is used in war
and therefore this acid can be seen as under other goods.
Court rejected this argument and said that, unlike this instance, the crown can also
prohibit bread imports.
Presumptions
 Words in a statute are used precisely and not loosely. This is an extension of
the literal rule of interpretation.
Case Law – Mayor (Plymouth) v. Taranakey Electricity Board

Municipal Corporation Act allowed an electric supplier of a particular borough to
contract with the local authority of any adjoining district to supply electricity to such
local authority.
Issue: Whether the board is allowed to contract with neighbouring districts?
Neighbouring means adjoining. Adjoining means sharing boundaries. This is to be
read precisely and cannot be interpreted loosely to mean neighbouring boroughs.
Thus, the board is not allowed to do so.
Mensrea
 Generally required for a criminal act.
 A statute may define a state of mind as an element of an offence, either by
express words or by implication or by being silent.
 Unless mensrea is ruled out by necessary implications, a court should be
zealous and guard the liberty of a subject and not find a man guilty unless he is
proved to have a guilty mind.
Case Law – Hari Prasad Rao v. State

After WW2, petrol was rationed. The supplier was required to ensure that petrol was
only provided against specific coupons and at the time of exchange. No advance
payments would be accepted. No person shall furnish or acquire petrol otherwise than
in accordance with the provisions of their order.
Clause 5: motor spirit required for any vehicle not covered by clause 3 or 4 shall be
furnished or acquired only against the surrender to a supplier at the time of supply of
valid ordinary coupons only in accordance with any condition or instructions
appearing on or attached to coupons.
Rule 81(4) states if any person contravenes any order made under his rule, he shall be
punishable with imprisonment for a term, which may extend to 3 years or with a fine
or both.
Clause 27(a): When motor spirit is furnished against the surrender of one or more
coupons the supplier shall immediately endorse or cause to be endorsed on each
coupon to surrender the registration mark of the vehicle to which the motor spirit is
furnished.
Rao was a supplier and his agent did not follow these rules in Rao’s absence. He was
charged with violation under clause 21 and 27 for supplying and for not endorsing.
For clause 22 – mensrea required, general provision (no person…) and only agent is
liable.
For clause 27 – it requires that supplier endorse coupons specific to the obligation of
supplier, failure to do so it will be the supplier’s responsibility and he will be held
liable.
Case Law – Sarju Prasad v. State of UP

Facts: This case is regarding the adulteration of food and its sale.
Prevention of Adulteration of Food Act: Section 7: No person shall himself or by any

person on his behalf shall sell any adulterated food.
Section 1: Any person himself or by any person on his behalf sells any article of food
in contravention of any provisions of this Act, he shall be punishable. Sarju was an
agent of Thakur Gill and he was caught selling adulterated oil.
Issue: Whether Sarju is liable for having sold the oil?
Claim – agents are generally not aware of adulteration in the goods that they sell.
Held: We know Thakur is definitely liable. Generally you are expected to know what
you are selling. However it can be proved otherwise. If it can be showed, then your
liability decreases. Thakur was held liable. Sarju’s punishment was mitigated owing
to circumstances.
Case Law – Ranjit Uddeshi v. State of Maharashtra

Ranjit was on of the partners of book firm that owned a bookshop. It found to be in
possession of sale of copies of an obscene book called Lady Chatalet’s lover, the
unexpurgated version which interalia contained obscene matter. Ranjit was prosecuted
u/s 292 of IPC. Is he liable?
Claim: he was not aware that it was an obscene book.
Does mensrea extend to requiring knowing the content of the book before putting it
into circulation?
Specific mensrea is not required because then every bookseller would be required to
know the contents of every single book and would be needed to be proved also.
# Whether the Government is affected by a statute?

 In English law, the crown generally considered not to be implicated in any
statute unless expressly provided.
 In Indian law, legislature that excluded the crown specifically mentioned why
they did so.
Case Law – UOI v. Jubi & Duniya

Land Reforms Act, post independence and there is no crown present in India.
Issue: Whether the legislation generally applies to the Union or whether it has to
expressly made to be applied to the Government?
Issue: Whether a tenant on the land owned by UOI claim transfer of land to his name
under the Act?
Owner is not an individual but the UOI.
Held: Court ruled yes. The UOI is necessarily that government is affected and it is
presumed to be included unless expressly excluded.
#Prospective Application of Law

 Laws are generally made to be prospective unless expressly made
retrospective.
Case Law – Pyarelal Sharma v. MD

Facts: Pyarelal was an employee under the J&K India Ltd, a state owned company
that qualifies as a state. Fundamental rights can be enforced against it if there is a
violation. The company had certain rules related to letting go of an employee – state
legislation
2 grounds were post abolished or medical grounds that required 3 months notice.
2 additional grounds were added in April with respect to leave on unauthorized

grounds and take part in active politics.
Leave ended in March and Pyarelal went back to work. On April 31 st his services
were terminated. His unauthorized leave ended in March and he has joined work.
Held: He is not liable and no retrospective application will be allowed since it is not
expressly provided by the Act.
# Statutes are not intended to be contradicting international law

 Courts will adopt that interpretation that will not be in conflict with rights and
obligations flowing with international law.
 If there is an inconsistency municipal law will prevail. Choose that
interpretation that goes along with the international law.
ADM Jabalpur – J. Khanna’s dissent – Article 21 can’t be suspended during

emergency.
Universal Declaration of Human Rights (UDHR)
Under Art 359 of the Constitution, the President can suspend fundamental rights at the
time of emergency. Now the question is whether Article 20+21 be suspended as well?
J. Khanna uses the rule of consistency with international rule of UDHR and says that
state can’t suspend Art 20+21. But this was a dissenting judgment and later on we had
the 44th Constitutional Amendment where it was said that Art 20+21 couldn’t be
suspended during emergencies.
Monist v. Dualist
Monist – International law once signed becomes national law/municipal law. Example
– China and Japan.
Dualist – International law to become enforceable has to be separately enacted in
national laws. Thus, it is not subservient to international law. Example – India and
USA.
# Legislature doesn’t make mistakes or commit omissions

 If the precise words of the statute are plain and unambiguous, we are bound to
construe them in an ordinary sense, even if it leads to absurdity or manifest
injustice.
 Words can only be modified if meaning is obscure.
 The duty of the court is to construe law as it stands and not to make laws.
 No court is competent to proceed on the presumption that the legislature made
a mistake because there is a strong presumption that the legislators don’t make
mistakes.
 Clerical or printing errors may be corrected as can an accidental omission in
the schedule.
Case Law – Nalinakhya Baisakh v. Shyam Sundar

Issue: Whether a statute that provides certainty in relation to a decree extends in
orders passed by the Court?
Facts: Tenant didn’t pay rent.
Held: The court rules that when the rule says decree, it does not include order.
Marginal notes have no say when the text of the statute is clear. Therefore, no
vacation of order.
# Presumption relating to jurisdiction

 There are 3 possible cases:
 A liability exists in common law and a statute provides for a specific
remedy. Both statutory and common-law remedies co-exist unless
statutory law exhausts the common law remedies.
 The right to sue is provided for in statutes without a specific remedy. In
such a case only the common law remedy will be available.
 The statutes create a liability not existing in common law. In such a case,
remedy exists only under the statutory law.
 Common Law court is the High Court whereas a Statutory court is the court of
summons.
Case Law – Barraclough v. Brown

The Harbors Docks and Piers clauses Act, 1847 provided for remedies to undertakers
in relation to works done in order to recover ships sunk in rivers. This gave
undertakers the rights to get costs/damages from the owners for the recovery.
The appellant was an undertaker and brought a suit against the respondents for
recovery of costs for damages during recovery of wreckage.
Queens bench - common law court was

It is a statutory right where the right and the remedy go together and therefore
jurisdiction will vest in the court of summary juris.
Case Law – Tyx Granite Co. v. Ministry of Housing

The Town and Country Planning Act, 1947 restricted the owner rights to deal with
their own land for development and provided that permission is required from the
local authority in order to engage in any development. An exception was granted to
any development authorized by any local or private act of the Parliament, which may
be undertaken without permission.
Tyx was authorized to develop i.e., quarrying certain lands in certain areas of North
Malvern under the private act of Parliament. (Malvern Hills Act) They bring a case
against the local authority that they don’t need permission as they are authorized.
Case in High Court, MoH claims no jurisdiction of the court…..
# Legislature knows existing laws

 Legislature doesn’t intend to alter an existing statute except by express
enactment.
Case Law – Abdul Rahim v. Syed Barkat

There is a waqf property inherited by some people. Land had a mosque and other part
had tenants. Court agreed that mosque was waqf’s property only and other part was
secular property inherited by the sons. Few years later, some random people bring in a
case against the heirs saying that the entire property was waqf property under section
92 of CPC.
Reliefs included:……
Whether relief could be granted to 3 rd party who are of a public nature? Whether
clause (h), which was an amendment, allowed the court to grant remedies to the 3 rd
party.
Internal Aids to Construction
Consists of Preamble, Conjunction, Objects and purposes, title and illustrations,

headings and marginal notes and punctuations.
Usually they do not stand on their own but act as aids internally within a statute to
arrive at an interpretation.
The Long Title

 The Transfer of Property Act, Muslim Women’s Act, etc.
 Descriptive in nature.
 The part in brackets is usually the long title.
 It gives the objective.
 Can’t control the real meaning within the main provisions.
 May be used to solve ambiguities.
 Most internal aids fall under this description because they cannot alter the
main meaning of the Act but can be used to solve ambiguities.
 The preamble of the constitution is to be read as a whole but the preamble
alone cannot be seen as a source of any prohibition or limitation. Preamble is
not a source of law.
Headings
 Essentially include the sub-titles and sub-headings.
 Headings, like titles, cannot be used to restrict the plain terms of an Act.
Marginal Notes
 These are the ones we find at the side of the statutes.
 They cannot be referred to for the construction of an Act and cannot control
the meaning of the Act.
 They are like a post-it flag in the textbook.
 They are not added by the legislature, often added by the publication house of
the book.
 If the legislature has enacted the marginal notes, they can be referred to, to
understand the statute but should be avoided as a general rule of interpretation.
They cannot alter the meaning.
Punctuations
 Before 1850s, punctuations weren’t used in enactments.
 Generally cannot alter the plain meaning of a statute, as it should be first read
without punctuations. If the meaning is clear and unambiguous without the
punctuations, then the punctuations must be disregarded.
 If there is an ambiguity, punctuations may be used to resolve that ambiguity.
Illustrations
 Useful in understanding the provisions and are of value.
 Should not be rejected as repugnant to the section but should not be
considered as being co-extensive with the section itself. Doesn’t exhaust the
operation of the section.
Definitions
 Blind interpretation of words in a statute.

 Definitions in other statutes should not normally be used in the construction of
words in other statutes.
 Exception is w.r.to General Clauses Act.
 However if the words of one statute seem to be in pari materia with another
statute, such words may be used to understand the other statute.
Schedules
 They form a part of the statute and are part of the enactment.
There are some subsidiary internal aids like provisos and non-obstante clauses
Provisos
 Exempt particular situation and circumstances from the operation of the
preceding clause in the Act.
 They do not imply that any other exemption is to be excluded from the Acts.
 Bit it can be understood to imply that but for the proviso, the exempting
situation or circumstances would be affected by the Act.
 Can either apply to a section or the entire Act and can be extensive as possible.
Non-Obstante Clauses
 It has an overriding effect on the operation of legislature and enactments to
such a clause.
 Usually starts with notwithstanding…
 Overriding affect on the referred section in the clause.
 If the clause states notwithstanding anything contained in any other law, it
means that all other laws are overridden but something in the same statute is
not overridden.
 Notwithstanding anything contained in this Act means other laws will still
apply and are not overridden by the application of this clause.
 Notwithstanding anything contained in any enactment has an overriding effect
on all the laws but not things that are not mentioned in any enactment like
PNJ, customary law etc.
Case Law – DOI v. Shrinbai Irani

The Defense of India of rules allowed for reacquisition of property during war. They
were supposed to lapse on 30th September 1946. Consequently any reacquisition of
property would also lapse.
The respondents’ property was reacquired through an ordinance for a period of the
present war and 6 months thereafter. In August 1946, the controller of the govt sent a
notice stating that the reacquisition order would expire on 30 th September 1946 and
requested the respondent to let the govt stay on the property as tenants. Negotiations
failed and the govt continued to occupy the property. On September 26 th 1946,an
ordinance was passed stating that, Notwithstanding…
Case Law – P.E.K Kalyaniamma v. K. Devi
Issue: The question of legitimacy of heirs in a bigamous marriage. Whether the 2 nd
wife and children could inherit their father’s property despite the fact that the 2 nd
marriage was void?
Under the HMA, the children are statutory legitimates. Marriage happened before the
HMA. Madras province had a rule invalidating the marriage. HMA repealed all such
rules and bigamous marriages are void u/s 11. Section 16 of HMA has a non-obstante
clause.
First wife claims that this marriage was anyway void under the previous rule before
HMA was enacted and therefore the non-obstante clause only applies to section 11 of
the HMA.
Article 14 is also argued – arbitrary distinction between void marriages before and
after HMA.
Held: Court ruled in favour of the 2nd wife and her children.
Legal Fiction
 Anything created by law, which factually might not be true but is deemed to
be so by law.
Case Law – Dargah Committee v. State of Rajasthan

Facts: The Municipal Committee of Ajmer carried out certain repairs that the dargah
committee had failed to carry out under the Ajmer Mewara Municipality Regulations,
any money recoverable by the committee shall be recovered as if it were a tax levied
by the committee on the property and shall be charged thereof.
Issue: Whether such a tax imposed could be appealed as if it were a tax?
Held: Court says you must carry a legal fiction to its logical end. If the fiction is that
of a tax, it may be appealed as a tax.
Shall Provisions
General rule is that an absolute enactment must be obeyed exactly but its sufficient if
a directory enactment be obeyed or fulfilled substantially. When a public duty is
imposed and a statute requires that it shall be performed in a certain manner, such
prescription may well be regarded as intended to be directory only in cases when
injustice or inconvenience to others who have no control over those exercising the
duty would result if such requirements were essential and imperative.
Case Law – DV Usman v. Food Inspector

Food adulteration Rule – public analyst shall within the period of 45 days from the
date of receipt of any sample for analysis deliver to the local authority, a report of the
result of such analysis.
In this case, samples of ‘paan supari’ were taken for analysis. The report was
submitted late. The appellant claims that prosecution cannot happen as the report was
delivered late.
In this case, food adulterer is causing injustice and it will be considered as a directory
provision.
It might mitigate the value of the analysis if the public official doesn’t do it properly.
And v. Or provisions
Case Law – Fed. Steam Navigation Co. v. Department of State and Inland
Issue: Whether the phrase ‘or’ in a statute precluded the use of both items on either
side of ‘or’?
The Act allowed the prosecution of ‘the owner or the master’. Prosecution attempted
to prosecute both if claimed that the prosecution had to pick and prosecute only one of
them.
Held: The court ruled that ‘or’ can be read as ‘and-each’. ‘And’ would have meant
that you should be both the owner as well as the master of the ship.
Case Law – R v. Oakes

The Official Secrets Act, clause 7 states that any person who aids or abets and does
any act preparatory to the commission of an offence under the Principle Act or this
Act shall be guilty of a felony.
If you only abetted but did not do any preparatory act, would you still be prosecuted?
‘And’ could be seen as an error and read as ‘or’. However its not generally that and
this can be done.
External Aids to Construction
These are subsidiary rules of interpretation and can used in case of ambiguities.
1. Parliamentary History
Case Law – R v. Allen

Whether the person will be prosecuted for bigamy?
Law – Whomever being married shall marry any other person during the life of the
former husband or wife shall be guilty of felony.
Accused had married second time. He claimed that this cant be taken into account
because it is void as the first marriage was subsisting. If this were true nobody could
ever be prosecuted for bigamy.
Case Law – Sheikh v. State of Maharashtra

Validity of the Maharashtra Control of in light of the unlawful activities prevention
(amendment) Act was under question.
The Maharashtra act in section 2 refers to preventing insurgency whereas it’s a state
act and list II under entry I only lists public order. The idea is that insurgency is very
different than public order.
Whether this would be effectively overridden by the unlawful activities act?
List I provides for defense of India.
Court goes into the objective of the Maharashtra act. It goes into the parliamentary
history. The act itself has the objective and control of and coping with certain
activities by organized crime syndicates or gangs and for matters connected therewith
or incidental.
The act itself defines continuing and organized crime to include promoting insurgency
in the pith and substance it is in fact dealing with organized crime.
2. Historical facts surrounding circumstances

There can be taken into account for interpreting specific words. Example – statutes
written long time ago and the language has changed.
3. Later political, social, scientific and economic developments

Case Law – R v. R
Dealt with the question of rape. The sexual offences act states that a man commits
rape if he has unlawful sexual intercourse with a woman who at the time of the
intercourse does not consent to it. Section 1(1) provided it’s a felony for a man to rape
a woman.
A man raped his wife under common law, under historical judgment a husband can’t
be convicted of rape committed by himself upon his wife for by mutual matrimonial
conduct and contract. The wife has given up herself in this time into her husband,
which she can’t retract.
Does the new act criminalize marital rape?

Court does take social advancements into consideration. The idea of lawful being
equated with outside the bounds of marriage is not the most natural meaning of the
term unlawful. Therefore even within the bounds of marriage if its unlawful, it is
unlawful.
4. Dictionaries
Can be used to ascertain meaning of a word where it is ambiguous.
5. Foreign Decisions
Can be used to interpret statutes where words are ambiguous. Can also include foreign
enactments.
Case Law – M V Elizabeth v. Harvan Investments

In this case the issue was whether the High Court of Andhra Pradesh had the
jurisdiction to rule upon the case. The Supreme Court of India referred to the
Admiralty Courts Act 1860 of the UK where the UK legislation had expanded the
jurisdiction of the High Courts of England and Wales to be coextensive with that of
the Admiralty courts. Although the Act did not apply to Indian Courts, the High Court
exercised its jurisdiction and the reasoning given was that the jurisdiction of the
Indian High court cannot be restricted because of the failure of legislature and held
that the power Indian High Courts was coextensive to the power of High Courts in
UK. Hence we can see that a foreign enactment has been used as an external aid of
interpretation as an independent principle rather than a subordinate principle.
6. Other Legislation
Legislation that is in pari materia can be used to discern the meaning of an ambiguous
statute. This can include statutes enacted on a later date.
Case Law – Tirumanikam v. State of TN

Question on TN GST Act 1959, which allowed for the refund of sales tax for goods
that were sold in the course of interstate trade.
To whom should this refund go (The payer or the dealer in the trade)?
The statute wont clear but an amendment was enacted in 1972, which provided the
refund to be given to dealers.
Case of 1960 – Legislation clarified. Thus, courts used the second legislation to solve
the question. Although the amendment was enacted on a later date, it was in pari
materia. Therefore it can be used.
7. Effect of usage and practice

The trade practices can be used to interpret an ambiguous legislation that deals with
that particular trade.
Case Law – N.Sureshnathan v. UOI

Question dealt with promotion of individual possessing 2 different kinds of degrees. If
the degree was an engineering one from a recognised college officers can be
promoted after 3 years of working in PWD.
If it were a diploma in civil engineering then promotion after 6 years would be given.
The appellant obtained a degree from a recognised college after 3 years of working.
Now would these 3 years of work before obtaining degree enough as a criteria?
The usual trade practice was that experiences were counted after obtaining the degree.
Therefore these 3 years will not be counted.
Construction of Specific Statutes
Tax Statutes
 Under Article 265, no tax may be levied under express authority of law.
 Taxes are essentially income of government. (Tax v. Fees)
 Any tax is a compulsory exactation of money imposed in order to raise
revenue for the government.
 Because there is an authority by law, tax statutes have to be strictly construed.
 If ambiguous, benefit is to be given to the assessee.
 Hardship and equity have no role to play in the interpretation of taxation
statutes.
Case Law – State of Punjab v. Jalandar Vegetable Syndicate

Case brought under the East Punjab Sales Tax Act which allowed the tax of firms. It
includes JVS during its operation. However in the assessment year, the partnership
was dissolved and the firm ceased to exist. The Act did not provide any machinery to
tax any dissolved firm.
Can such a firm be taxed?
There is an ambiguity with respect to dissolved firms. Therefore, tax will not be
imposed as per the strict interpretation.
Case Law – Atlas Cycles v. State of Haryana

An ordinance provided for the inclusion of the region in which Atlas cycles operated
within the municipality of Sonepat and this tax provision extended to the newly
included areas. All rules, by-laws, orders, directions and powers imposed in the
Sonepat district.
Would such tax be applicable to Atlas Cycles?
Strict construction – notifications are not inclusive in the ordinance. It will not apply
to newly extended areas and hence, no application on Atlas cycles.
Case Law – Commissioner of Income Tax v. Karamchan Premchand

Question was in relation to interpretation of Business Profit Tax Act. The provision
stated that the tax was not to apply to any incomes, profits, or gains accruing or
arising within any part of India to which the tax does not apply unless such incomes,
profits or gains were received in or brought into taxable areas.
The assesse had carried out business both within and outside such territories. He
claims that the losses from business carried out outside the territory can be off-set
with the profits earned within the territory. Because it was unclear, benefit given to
the assessee.
Penal Statutes
 Also constructed strictly because of Article 21 of the Constitution.
 If more than one construction or ambiguity exists, the more beneficial to the
convict is to be used.
 Rules of strict construction
 If a law covers a particular class, it cant be extended to people outside the
class.
 If its possible to have a wider and a narrower construction of a statute and
there is no indication of any policy in the statute itself, the narrower
construction should be used.
 In Rule 2, if there is a policy indicated while reading a statute as a whole
and that policy directs a wider construction, it will be used.
 If a clause in the penal statute is unintelligible or absurd or socially
harmful but statute is read as a whole can interpret such clause to cure such
defect, then this interpretation will be used.
Case Law – Narayan Nambiar v. State of Kerala

This is in relation to a clause in Prevention of Corruption Act.
Clause – if a public servant by correct or illegal means or by otherwise abusing his
position as a public servant obtains for himself or for any other person any valuable
thing or pecuniary advance he could be punished for corruption.
The public official undervalues land of the government that was intended for
allotment to the landless in anticipation of it being allotted to his brother in law.
Counsel for the appellant claims that this section doesn’t cover loss to government as
a part of things done by the public servant that amounts to corruption. Land was
anyway going to be allotted. Therefore the loss was to government but no profit to
appellant or brother in law.
Long title of the Act is prevention of bribery and corruption. Would this devaluation
of land amount to corruption?
Rule 3 applies and there is clear indication of policy. He could be held for corruption
as clause provides that he abused his position.
Case Law – Fisher v. Bell

Restriction of Offensive Weapons Act prohibited the manufacture, selling, hiring,
offering for sale/hire, lending it giving to any person weapons as described and
includes flick knives.
A shopkeeper displayed in a window a flick knife with the price. Can he be held
liable?
It is an invitation to offer ad not offer to sale. This invitation to offer is not prohibited
by the statute. Therefore, not held liable.
Remedial Statutes
 Comes into existence for public policy demands and generally receive a liberal
construction.
 If 2 interpretations are possible, the one that furthers the purpose of the Act
will be preferred as long as no violence is done to the language of the Act.
 Exceptions will be narrowly constructed.
Case Law – Western India Plywood v. P. Ashokan

Certain benefits were given to any worker injured in the course of employment. Once
you’ve taken compensation, you cannot seek compensation again under any other law
in force.
This worker had already taken his compensation but sued for compensation under
torts.
The clause said ‘law in force’ not ‘enactment in force’. Torts is a law.
Benefit may or may not be monetary in these cases.
Case Law – Municipal Corporation v. Female Workers

Issue – Whether the benefits under the Maternity Benefit Act could be extended to
women in the muster rolls of MCD.
This benefit applies to employees (minimum 240 days). These workers were on
contract basis. However these women argued that they have been working for 10 or
more years as their contracts were being renewed continuously.
Holding – Remedial statutes are to be liberally constructed and muster rolls did not
change from year to year and essentially employees must apply. Court also applied an
external aid in the form of CEDAW.
Case Law – Bangalore Water Supply & Sewage Board v. Rajappa

Issue – Who is a workman? What should be the nature of work for someone to be
called a worker? To what extent would be covered under the Industrial Disputes Act?
Holding – J. Krishna Iyer tried to include every industry possible. This included law
chambers, educational institutions and every other service provided. However a
Caveat was added. Example, lawyers in a law chamber won’t be considered as
workers but clerks would be. Changed the initial intention of the legislation of the
Act. Therefore, this interpretation was applied to this case also.
What is the Nature of precedence in India and USA?

The nature of precedents in other countries is hard and fast. In India, over the last 50
years, cases have been flipped 180 degrees several times.
In the USA, no Parliamentary supremacy but judiciary has some permanence, as
Supreme Court judges don’t retire. This permanence has failed to emerge in India.
Therefore Supreme Court tends to be very active in overruling its precedents.
Example – Keshavananda Bharti, ADM Jabalpur (by the 44 th Amendment) and
Kharak Singh cases.
Case Law – Abhiram Singh Case

Under section 123(3) of Representatives of People’s Act, it defines one kind of
corrupt practices only.

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20161482 Interpretation of Statutes Avinash Alladi

Interpretation of Statutes – Notes

Philosophical arguments – see why we need rationalized judgment?

Why are reasoned judgments important?

Case Law – Riggs v. Palmer

Issue - What about inheritance?

Case Law – Plessey v. Ferguson

Case Law – Brown v. Board of Education

Antonin Scalia v. Stephen Breyer on the Constitution debate

What is the role of the judge?

Chain Novel Theory

Rule Skepticism and Speluncean Explorers

- Rule skepticism – legal realism movement.

Eskridge’s Theory of Practical Reasoning

- Speaks about textualism and chain novel theory.

- This is not a hierarchy as proposed by Eskridge. However, practically, this is how a

Case Law – United Steelworks v. Weber (1979)

Case Law – Griffin v. Oceanic Constructors

Case Law – B.N.Mutto v. T.K.Nandi

Case Law – Ramawatar v. Assistant Sale Tax Officer

Case Law – Moti v. State of Bihar

Case Law – State of West Bengal v. Washi Ahmed

Case Law – Narayan Swami v. Paneerselvam

Case Law – S.R.Batra v. Tarana Batra

Case Law – Hayden’s (1584)

Case Law – RMD Chamarbaugwala v. UOI

B. Subsidiary Rules of Interpretation

(i) Rule of Harmonious Construction

(ii) Ut Res Magis Valeat Quam Pereat

Case Law – Avtar Singh v. State of Punjab

(iii) Expressio Unius Est Exclusio Alterius

Case Law – Khemka & Co. v. State of Maharashtra

(iv) Noscitur A Sociis

Case Law – Commissioner of customs and excise v. Savoy Hotels

Case Law – Director of Publication Pros v. Jordan

Case Law – Siddheswari Cotton Mills v. UOI

Case Law – Attorney General v. Brown

Case Law – Mayor (Plymouth) v. Taranakey Electricity Board

Case Law – Hari Prasad Rao v. State

Case Law – Sarju Prasad v. State of UP

Prevention of Adulteration of Food Act: Section 7: No person shall himself or by any

Case Law – Ranjit Uddeshi v. State of Maharashtra

# Whether the Government is affected by a statute?

Case Law – UOI v. Jubi & Duniya

#Prospective Application of Law

Case Law – Pyarelal Sharma v. MD

2 additional grounds were added in April with respect to leave on unauthorized

# Statutes are not intended to be contradicting international law

ADM Jabalpur – J. Khanna’s dissent – Article 21 can’t be suspended during

# Legislature doesn’t make mistakes or commit omissions

Case Law – Nalinakhya Baisakh v. Shyam Sundar

# Presumption relating to jurisdiction

Case Law – Barraclough v. Brown

Queens bench - common law court was

Case Law – Tyx Granite Co. v. Ministry of Housing

# Legislature knows existing laws

Case Law – Abdul Rahim v. Syed Barkat

Internal Aids to Construction

Consists of Preamble, Conjunction, Objects and purposes, title and illustrations,

The Long Title

 Blind interpretation of words in a statute.

Case Law – DOI v. Shrinbai Irani

Case Law – Dargah Committee v. State of Rajasthan

Case Law – DV Usman v. Food Inspector

Avinash Alladi's IOS Notes

Avinash Alladi's IOS Notes