When are External Aides to Construction Needed

Interpretation of Statutes
Assignment

Submitted by:
Name: SYED MOOSA
Student ID: 202004824
Class Roll No.: 17
Examination Roll No.: 20BLWS160
Course: BA.LLB
Semester: 6th
Batch: Self Finance

Submitted to: Dr. Sohail Nazim

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 TABLE OF CONTENTS

1. CHAPTER 1………………………………………………………….…….2-4

a. INTRODUCTION………………………………………………..…2

2. CHAPTER 2…………………………………………………….………….5-6

a. MEANING AND CONCEPT

3. CHAPTER 3……………………….……………………………………….7-15

(a) PARLIAMENTARY HISTORY …………………………………..7

(b) HISTORICAL FACTS …………………………………………….9

(c) LATER SCIENTIFIC INVENTIONS ……………………………..9

(d) HEADINGS……………………………………………………..….11

(e) REFERENCE TO OTHER STATUTES ………………….………..12

(f) USE OF FOREIGN DECISIONS …………………….………...…..13

(g) OTHER MATERIALS…………………………………….………..14

(h) TEXTBOOKS ……………………………………………………....15

(i) DICTIONRIES………………………………………………………15

4. CONCLUSION……………………………………………………………...16

5. BIBLIOGRAPHY……………………………………………………………17

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 CHAPTER 1
INTRODUCTION
Context of the Study:

The interpretation of law is critical to the operation of legal systems all over the world. Laws
cannot be always clear-cut, and it frequently necessitates the use of extra instruments and
assistance to understand its intended meaning. External aids to interpretation are sources other
than the legislation that can help grasp legislative purpose, such as parliamentary history,
precedents, principles of law, and cultural background. The purpose of this study is to investigate
the importance, extent, and usefulness of external assistance in legal interpretation.

Statement of Problem:

This study examines the issue of ambiguity and complexity in legal documents, which causes
difficulty in accurately understanding the law. The application of external aid is required because
legislation lack precise guidelines. However, concerns have been raised about the dependability,
relevance, and limits of these aids, which can have an influence on the correctness and consistency
of legal interpretations.

Research Questions:

1. What are the main forms of external aid utilised in legal interpretation?

2. How do external aid help to resolve ambiguity in legal texts?

3. What are the limitations and problems of using external aid in understanding the law?

4. How can the efficacy of external help be increased to guarantee more uniform and correct legal
interpretations?

Scope of the Research:

1. Examine several sorts of external aids, including Parliamentary History, Historical Facts and
Surrounding Circumstances, Later Scientific Inventions, Reference to Other Statutes (pari
materia) & Use of Foreign Decisions

2. Case study analysis demonstrating the application and influence of external aids in legal
interpretation.

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3. An assessment of the limitations and problems of utilising external aids in various legal
jurisdictions.

4. Discussion of prospective changes or suggestions for enhancing the use of external aids in
interpreting the law.

Significance of the Research Assignment

This study project is noteworthy because it highlights the critical role that external aids have in
effectively and consistently interpreting the law. The study intends to contribute to the
establishment of a more strong and trustworthy framework for legal interpretation, assuring
justice, fairness, and predictability within legal systems by investigating their relevance and
limitations.

Hypothesis

The hypothesis for this study project is that using external aids improves legal interpretation by
giving more context and advice, therefore enhancing the correctness and reliability of legal
choices.

Objectives of the Research Assignment:

1. Recognise and analyse the various forms of external aids employed in legal interpretation.

2. To evaluate the effectiveness of external aids in resolving misunderstandings and explaining

legislative meaning.

3. To investigate the limitations and constraints of using external aids in legal interpretation.

4. To make recommendations for improving the efficacy and dependability of external aids in legal
interpretation.

Methodology:

The research will use qualitative methodologies. The application and influence of external aids in
legal interpretation will be investigated using qualitative approaches such as case studies. To
acquire empirical information on the efficacy and consistency of legal interpretations using
external aids.

Literature Review

The literature study will include academic publications, books, legal opinions, and pertinent legal
precedents pertaining to the interpretation of law and the use of external aids. It will investigate

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the historical evolution, theoretical foundations, and practical consequences of external aids in
various legal systems. The evaluation will offer a thorough grasp of the present state of knowledge
in the subject and will identify gaps that the study will attempt to fill.

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 CHAPTER 2
MEANING AND CONCEPT
“By interpretation or construction is meant”, says Salmond, “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”. 1A statute is an edict of the Legislature2 and the conventional way of interpreting
and construing a statute is to seek the intention of itsmaker. A statute is to be construed according
“to the intent of them that make it” and “theduty of judicature is to act upon the true intention of
the legislature- the mens or sentential legis.3

There are two types of aids to interpretation- The internal and the external aids. The
following are considered internal aids to interpretation-
• Long Title- it is now settled that Long Title of an Act is a part of the Act and is
admissible as an aid to its construction.5 4 The title although part of the Act is in itself
not an enacting provision and though useful in case of ambiguity of the enacting
provision, is ineffective to control their clear meaning.6 5
• Preamble- the preamble of a statute like the long title is a part of the Act and isan
admissible aid to construction. Although not an enacting part, the preamble is expected
to express the scope, object and purpose of the Act more comprehensively than the
long title.
• Preamble of the Constitution- the majority judgments in Keshavananda Bharti7 6 and
Minerva Mills8 7 relied upon the Preamble in reaching the conclusion that the power
of amendment conferred by Art 368 was limited and did not enable parliament to alter
the basic structure of the Constitution.
• Headings
It is widely accepted that the headings or titles placed before sections or groups of
sections can be consulted when interpreting a legislative act.

• Marginal Notes- one cannot ignore the fact that the headings and sidenotes are
included on the face of the Bill throughout its passage through the legislature. They

1
See., Salmond, Salmond on Jurisprudence, p.152 (Sweet and Maxwell,11th edition).
2
Vishnu Pratap Sugar Works Ltd. V. Chief Inspector of Stamp, UP, AIR 1968 SC 102
3
Supra note 2.
4
R. v. Secretary of State for Foreign and Commonwealth Affairs, (1994) 1 All ER 457
5
Manoharlal v. State of Punjab, AIR 1961 SC 418: R. v. bates and Russell, (1952) 2 All ER 842
6
Keshavananda Bharti v. State of Kerala, AIR 1973 SC1461
7
Minerva Mills v. UOI, AIR 1980 SC 1789

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 are there for guidance. They provide a context for the examination of those parts of
the Bill that are open for debate. 10 8
• Punctuations

• Illustrations- They form part of the statute and although forming no part of the
section, are of relevance in the construction of the text of the Section.9
• Interpretation Clauses- it is common to find in a statute “definitions” of certain
words and expressions used elsewhere in the body of the statute. These definitionsare
generally very useful while interpreting the meaning of the ambiguous terms.
• Proviso- when one finds a proviso to a section the natural presumption is that, but for
the proviso, the enacting part of the section would have included the subject- matter
of the proviso.
• Explanation- an explanation is at times appended to a section to explain the meaning
of words contained in the Section.10
• Schedule- schedules appended to statutes form part of the statute. They are added
towards the end and their use is made to avoid encumbering the sections in the statute
with matters of excessive details.

External aids to interpretation of statutes include Parliamentary History, Historical Facts

and Surrounding Circumstances, Later Scientific Inventions, Reference to Other
Statutes (pari materia) & Use of Foreign Decisions. Each of the above mentioned
constituents of external aids to construction have been dealt briefly in the due course of my
work.

8
R. v. Montila, (2005) 1 All ER 113
9
Mohammad Sydeol v. Yeah Oai Gark, 43 IA 256
10
Bengal Immunity CO. Ltd. V. State of Bihar, AIR 1955 SC 661.

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 CHAPTER 3
PARLIAMENTARY HISTORY
The interpretation of statutes is a crucial aspect of legal practice and is essential for determining
the meaning and intention behind legislative provisions. While the primary source of
interpretation is the text of the statute itself, courts often rely on various external aids to better
understand and apply the law. One such external aid is parliamentary history, which refers to
the historical records and debates surrounding the passage of legislation. This write-up explores
the role of parliamentary history as an external aid for the interpretation of statutes and its
significance in the context of internal aids to interpretation of law.

Understanding Parliamentary History:

Parliamentary history encompasses the records and proceedings of the legislative body
responsible for enacting the law. It includes the debates, committee reports, speeches, minutes,
and other documents that document the legislative process leading to the enactment of a statute.
These records provide valuable insights into the purpose, intent, and context of the legislation,
helping to elucidate the meaning of the statutory provisions.

Significance of Parliamentary History as an External Aid:

Legislative Intent: Parliamentary history helps ascertain the intention of the lawmakers when
enacting a statute. By examining the debates and discussions in the legislature, courts can
understand the problems that the legislation sought to address, the objectives it aimed to achieve,
and the compromises made during its drafting. This knowledge assists judges in interpreting
and applying the law in a manner consistent with the original intent of the legislature.

Clarification of Ambiguities: Statutes may contain ambiguous or unclear language, leaving

room for interpretation. Parliamentary history can provide valuable context to resolve such
ambiguities. By analyzing the legislative debates, courts can discern the meaning intended for
contentious provisions and make informed decisions that align with the legislative purpose.

Legislative History as a Guide: When faced with an unclear provision, judges often turn to
legislative history as a guide. The records of previous versions of the legislation, amendments
proposed and rejected, and subsequent amendments can shed light on the lawmakers' intentions
and the reasons behind specific wording choices. This information helps judges determine the
scope and application of the statute in question.

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Resolving Conflicting Interpretations: Statutes can be subject to conflicting interpretations,
leading to legal uncertainty. Parliamentary history serves as a tool to reconcile such conflicts by
referring to the original legislative intent. By examining the legislative records, courts can
identify the purpose of the statute and apply it consistently, ensuring a uniform and coherent
interpretation across different cases.11

According to the traditional English view the Parliamentary History of a statute was not
considered as an aid to construction. The Supreme Court of India in the beginning enunciated the
rule of exclusion of Parliamentary History in the way it was traditionally enunciated by the English
Courts but on many an occasion, the court used this aid in resolving questions of construction.12

In Indira Sawhney v. Union of India13, while interpreting Article 16(4) of the Constitution
the Supreme Court referred to Dr. Ambedkar‟s speech in the Constituent
Assembly as the expression backward class of citizens’ is not defined. The court held that
reference to Parliamentary debate is permissible to ascertain the context, background and
objective of the legislatures but at the same time such references could not be taken as
conclusive or binding on the courts. Thus in the Mandal Reservation Case, the Supreme
Court resorted to Parliamentary History as an aid to interpretation.

In the Ashwini Kumar’s Case14(1952), the then Chief Justice of India Patanjali Shastri quoted
that the Statement of Objects and Reasons should not be used as an aid to interpretation
because in his opinion the Statement of Objects and Reasons is presentedin the Parliament when a
bill is being introduced. During the course of the processing of the bill, it undergoes radical
changes. But in the Subodh Gopal’s Case15(1954), Justice Das although he fully supported
Chief Justice Patanjali Shastri‟s views in the Ashwini Kumar’s Case16 but he wanted to use
the Statement of Objects and Reasons to protect the sharecroppers against eviction by the new
buyers of land since zamindari system was still not abolished and land was still not the property
of the farmers. So Justice S.R. Das took the help of Statements of Objects and Reasons to analyse
the social,legal, economic and political condition in which the bill was introduced.

11
Bengal Immunity CO. Ltd. V. State of Bihar, AIR 1955 SC 661.
12
AIR 1993 SC 477.
13
Indira Sawhney v. Union of India, AIR 1993 SC 477.
14
Ashwini Kumar Ghose v. Arabinda Bose, AIR 1952 SC 369.
15
AIR 1954 SC 92.
16
Supra at 4.

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 In Harsharan Verma v. Tribhuvan Narain Singh 17, the appointment of Tribhuvan Narayan
Singh as the chief minister of Uttar Pradesh was challenged as at the time of his appointment
he was neither a member of Vidhan Sabha nor a member of Vidhan Parishad. While
interpreting Article 164(4) of the Constitution, the Supreme Court held that it did not require
that a Minister should be a Member of the Legislature at the time ofhis being chosen as such,
the Supreme Court referred to an amendment which was rejected by the Constituent Assembly
requiring that a Minister at the time of his being chosen should be a member of the Legislature.

HISTORICAL FACTS

Historical facts refer to the events, circumstances, and conditions that prevailed at the time a statute
was enacted. They encompass the social, economic, political, and legal context that influenced the
lawmakers and shaped the legislative intent behind a statute. Analyzing historical facts involves
examining the prevailing norms, practices, and legal principles of the time, as well as
understanding the problems and issues that the legislature sought to address through the
legislation.

Historical facts are very essential to understand the subject matter of the statute or to have regard
to the surrounding circumstances which existed at the time of passing of the statute.The rule of
admissibility of this external aid is especially useful in mischief rule. The rule that was laid down
in the Heydon’s Case18 (1584), has now attained the status of a classic. The mischief rule enables
the consideration of four matters in construing an act:

• What was the law before the making of the Act?

• What was the mischief for which the law did not provide?

• What was the remedy provided by the Act?

• What was the reason of the remedy?

17
Harsharan Verma v. Tribhuvan Narain Singh, AIR 1971 SC 1331.
18
“Rules of Interpretation of Statutes,” Legalserviceindia.com, 2021available
at: https://www.legalserviceindia.com/legal/article-9454-rules-of-interpretation-of-
statutes.html#:~:text=Mischief%20rule%20is%20a%20rule,by%20the%20legislature%20is%20attained. (last
visited May 22, 2023).

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 This rule was applied in Bengal Immunity Co. v. State of Bihar19 in the construction of
Article 286 of the Constitution in which the Supreme Court held that a state has the legislative
competence to impose sales tax only if all the ingredients of a sale have a territorial nexus.
Thus on the same transaction sales tax cannot be imposed by several states.
Since the function of the court is to find the meaning of the ambiguous words in a statute, a
reference to the historical facts and surrounding circumstances that led to the enactmentassist
the courts in efficient administration of speedy justice. The rule permits recourse to historical
works, engravings, pictures and documents where it is important to ascertain ancient facts of
a public nature. Historical evolution of a provision in the statute is also sometimes a useful
guide to its construction.20

Limitations and Criticisms:

While historical facts are valuable in interpreting statutes, there are certain limitations and
criticisms associated with their use:

Selective Focus: Critics argue that reliance on historical facts can be selective, as judges may
choose to emphasize certain historical aspects that support their preferred interpretation, while
disregarding others.

Incomplete Historical Records: Historical records may not always provide a comprehensive
picture of the legislative intent or the societal context in which a statute was enacted. Gaps in
historical knowledge may limit the usefulness of historical facts as an external aid.21

Potential Anachronism: Interpreting statutes solely based on historical facts can lead to
anachronistic interpretations, where contemporary values and understandings are imposed on
historical events or conditions. Courts must strike a balance between understanding the
historical context and applying modern perspectives to avoid distorting the original legislative
intent.

19
Bengal Immunity Co. v. State of Bihar, AIR 1955 SC 661.
20
R. v. Ireland, (1997) 4 All ER 225
21
admin and admin, “EXTERNAL AIDS TO INTERPRETATION” Lawordo.com, 2019available
at: https://www.lawordo.com/external-aids-to-interpretation/ (last visited May 31, 2023).

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 LATER SCIENTIFIC INVENTIONS

The laws made in the past are applied in the present contemporary society in the light of
changed social, political, legal and economic circumstances taking into consideration the
advancement in science and technology. Statutes must be interpreted in accordance with the
spirit of the Constitution of India even though the statutes were passed before independence
of India or before the commencement of our Constitution. Later scientific inventions refer to
technological advancements, scientific discoveries, and innovations that occur after the
enactment of a statute. These developments can provide valuable insights into the context and
purpose of the legislation. By considering later scientific inventions, courts can better
comprehend the underlying principles and objectives of a statute and apply them in a manner
consistent with contemporary knowledge.22

The case State v. J.S. Chawdhry23 relates to Section 45 of the Indian Evidence Act, 1872
which only mentions about handwriting experts and not typewriting experts for the reason
that typewriters were invented much later than 1872.In the instant case the state wanted to use
the opinion of a typewriting expert as evidence in a murder case. The Supreme Court then
overruled its decision in the case Hanumant v. State of Madhya Pradesh24 which held that
the opinion of the typewriting expert was inadmissible as evidence in the court of law.

State of Maharashtra v. Dr. Prafulla Desai25 case relates to Section 388 of the Indian Penal
Code which deals with gross medical negligence resulting in the death of the patient. The
prosecution wanted to produce the statements of a New York Doctor Dr.Greenberg as
evidence. The problem arose when Dr.Greenberg refused to appear in the Indian Court to
record his statements. There is no such provision which can compel a witness residing outside
the domestic territory of India to come to an Indian court as a witness. Thus in such
circumstances video conferencing became the only viable option. But the accused opposed
video conferencing under Section 273 of Criminal Procedure Code which clearly says that
evidence can be recorded only in the presence of the accused. The Supreme Court interpreted

22
“External Aid of Interpretation,” Legalraj.com, 2020available at: https://legalraj.com/articles-details/external-
aid-of-interpretation (last visited May 31, 2023).
23
AIR 1996 SC 1491.
24
AIR 1952 SC 343.
25
AIR 1952 SC 343.

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 presence not merely as physical presence but asa situation in which the accused can see, hear
and question the witnesses.

Limitations and Criticisms:

While later scientific inventions can be a valuable external aid, there are certain limitations
and criticisms associated with their use:

Retroactive Application: Reliance on later scientific inventions may lead to retroactive

application of the law, imposing current scientific understanding on past events or
transactions. This can raise concerns about fairness and the stability of legal expectations.

Expert Testimony: Courts may require expert testimony to understand the technical aspects
of later scientific inventions. The admissibility and reliability of such testimony can be subject
to scrutiny and challenge.

Relevance and Context: The relevance and contextual applicability of later scientific
inventions must be carefully considered. Not all inventions will have a direct impact on the
interpretation of a statute, and courts must assess the significance and connection to the subject
matter at hand.

REFERENCE TO OTHER STATUTES

Statutes must be read as a whole in order to understand the words in their context. Problem
arises when a statute is not complete in itself i.e. the words used in the statuteare not
explained clearly. Extension of this rule of context permits reference to other statutes in pari
materia i.e. statutes dealing with the same subject matter or forming part of the same system.
The meaning of the phrase pari materia was explained in an American Case, United Society
v. Eagle Bank (1829) in the following words: “Statutes are in pari materia which relate to the
same person or thing, or to the same class of persons or things. The word par must not be
confounded with the word similes. It is used in opposition to it- intimating not likeness merely
but identity. It is a phrase applicable to public statutes or general laws made at different times
and in reference to the same subject”.26

26
See., Sigh G.P., Principles of Statutory Interpretation, 275(Wadhwa and Company, Nagpur, Tenth Edition, 2006)

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 In the case, State of Punjab v. Okara Grain Buyers syndicate Ltd., Okara27, the Supreme
Court held that when two pieces of legislation are of differing scopes, it cannot be said that
they are in pari materia. However it is not necessary that the entire subject matter in the
statutes should be identical before any provision in one may be held to be in pari materia with
some provision in the other.28

In the case State of Madras v. A. Vaidyanath Aiyer, the respondent, an income tax officer was
accused of accepting bribe. The Trial Court convicted him and awarded a rigorous
imprisonment of six months. When an appeal was made in the High Court, the High Court
set him free on the ground of a possibility that he might have borrowed the money and not
accepted it as bribe. The Supreme Court held the accused guilty and made an observation that
the judgement of the High Court was extremely perverse.

In the instant case, the Supreme Court held that Section 4 of the Prevention of Corruption
Act,1947, which directs that on proof that the accused has accepted any gratification other
than legal remuneration, it shall be presumed unless the contrary is established by the accused
that the gratification was accepted as bribe, has been held to be in pari materia with subject-
matter dealt with by the Indian Evidence Act,1872; and the definition „shall presume‟ in the
Indian Evidence Act has been utilized to construe the words „it shall be presumed‟ in section
4 of the Prevention of Corruption Act,1947.

USE OF FOREIGN DECISIONS

Reference to decisions of the English Courts was a common practice in the administration of
justice in pre independent India. The reason behind this was that the Modern Indian Legal System
owes its origin to the English Common Law System. But after the commencement of the
Constitution of India as a result of the incorporation of the Fundamental Rights, the Supreme Court
of India gave more access to American precedents.29

27
IBID
28
SUPRA 13
29
Mayank Shekhar, “External Aids to Construction | Explained” Legalbites.in (Legal Bites, 2017)available
at: https://www.legalbites.in/external-aids-construction/ (last visited May 31, 2023).

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It cannot, however, be doubted that knowledge of English law and precedents when the language
of an Indian Act was not clear or express, has often been of valuable assistance. Speaking about
Indian Codes Shri M.C.Setalvad has stated: “Where the language of the code was clear and
applicable, no question of relying on English Authority would arise. But very often the general
rule in the Indian Code was based on an English Principle and in such cases the Indian Courts
frequently sought the assistance of English Decisions to support the conclusions they reached.
They could not otherwise for not only the general rules contained in the codes but some of the
illustrations given to clarify the general rules were based on English decisions.”30

In the case General Electric Company v. Renusagar Power Company31, the Supreme Court of India
held that when guidance is available from Indian decisions, reference to foreign decisions may
become unnecessary.

Different circumstances may also result in non acceptance of English precedents by the Indian
Courts. In the case M.V.Elisabeth v. Harwan Investment and Trading Pvt. Ltd.32, the Supreme
Court differed from English decisions and interpreted the words

„damage caused by a ship‟ in Section 443 of the Merchant Shipping Act, 1958 as not
limited to a physical damage caused by a ship by reason of its coming into contact with something;
it intended to include damage to the cargo carried in a ship. The Supreme Court in this case differed
in its opinion because in India there is no other Act covering claim of damages for damage to the
cargo carried in a ship but in England this subject is covered expressly by a different Act.

OTHER MATERIALS

Supreme Court used information available on internet for the purpose of interpretation of
statutory provision in Ramlal v. State of Rajasthan. Courts also refer passages and materials
from text books and articles and papers published in the journals. These external aids are
very useful tools not only for the proper and correct interpretation or construction of statutory

30
See., Setalvad M.C., The Common Law in India , 61 as cited in Singh G.P., Principles of Statutory Interpretations,
327(Wadhwa and Company, Nagpur, Tenth Edition, 2006).
31
General Electric Company v. Renusagar Power Company, (1987)4 SCC 137.
32

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 provision, but also for understanding the object of the statute, the mischief sought to be
remedied by it, circumstances in which it was enacted and many other relevant matters. In
the absence of the admissibility of these external aids, sometimes court may not be in a
position to do justice in a case.

TEXTBOOKS

Text books may be referred to by the courts to arrive at the true meaning of an enactment. It is,
however, not necessary that the views expressed therein are the views of the court also. There have
been instances of both acceptance and rejection by the courts of the opinions expressed in text
books. Manu, Yajnavalkya, Vijnaneshwara, Jimutavahana and Kautilya have been frequently
quoted by courts with approval. Mulla has also been referred time and again.

In the English case of Bastin v. Davies,33 Lord Goddard C.J. says at one place, while interpreting
the word 'substance in the light of discussions in the twelfth edition of Sale of Food and Drugs by
Bell: "This court would never hesitate to disagree with a statement in a text book, however
authoritative, or however long it had stood, if it thought right to do so." He goes on to say, "it
would be unfortunate if doubt had to be thrown in a statement which has appeared in a well-known
text book for a greater number of years without being judicially doubted and after it had been acted
on by justices and their clerks for many years." In Kesavananda Bharati v. State of Kerala, 34 a
large number of text books were quoted but most of the Judges of the Supreme Court deciding this
case were of the opinion that in view of many opinions and counter-opinions it was not desirable
to follow the opinions and that the safest course for the court was to interpret keeping in mind
always the whole context of the issues.

DICTIONARIES

When a word is not defined in the statute itself, it is permissible to refer to dictionaries to find
out the general sense in which that word is understood in common parlance. However, in the
selection of one out of the various meanings of a word, regard must always be had to the scheme,
context and legislative history.

33
(1950) 2 KB 579.
34
AIR 1973 SC 1461.

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CONCLUSION
The chief source of law is legislation, though there are other sources of law such as precedents
and customs. Every source of law finds its expression in a language. Often thelanguage has a
puzzling effect, i.e., it masks and distorts. Often it is found that the language of a statute is not
clear. The words used in the statute too at times seem to be ambiguous. Sometimes it is not
possible to assign the dictionary meaning to certain words used in legislation. Meaning which
is to be assigned to certain words in a legislation. Even the dictionary does not give the clear-
cut meaning of a word. This is so because the dictionary gives many alternative meanings
applicable in different contexts and for different purposes so that no clear field for the
application of a word is easily identified. So long as expansion of meaning takes place
uniformly, the law will develop along healthy lines. But if one judge takes the narrow view
and the other the broad view, the law will mean different things for different persons and soon
there will be confusion. Hence, it is necessary that there should be some rules of interpretation
to ensure just and uniform decisions. Such rules are called rules of interpretation. There are
various aids to the rule of interpretation and in case the ambiguity is not removed even after
applying theinternal aids, then the external aids can come in handy. They provide various
methods by the help of which a statute can be interpreted and used by the judiciary in deciding
cases.

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Books:

• Craies, William Feilden. Craies on Legislation: A Practitioner's Guide to Statutes and

Statutory Interpretation. London: Sweet & Maxwell, 2020.

• Bennion, Francis. Bennion on Statutory Interpretation. 6th ed. London: LexisNexis,

2021.

• Maxwell, Sir Peter. Maxwell on The Interpretation of Statutes. 13th ed. London: Sweet
& Maxwell, 2019.

• Gans, Steven. The Concept of Statutory Interpretation. Oxford: Oxford University Press,
2020.

Websites:

• Cornell Law School Legal Information Institute. "Statutory Interpretation." Accessed

May 15, 2023. https://www.law.cornell.edu/wex/statutory_interpretation.

• Supreme Court of India. "Judgments on Interpretation of Statutes." Accessed May 18,

2023. https://main.sci.gov.in/judgments/interpretation-of-statutes.

• American Bar Association. "Guide to Statutory Interpretation." Accessed May 20, 2023.
https://www.americanbar.org/groups/gpsolo/publications/gp_solo/2013/july_august/gu
ide_to_statutory_interpretation/.

• Law Commission of India. "Report on Interpretation of Statutes." Accessed May 22,

2023. https://lawcommissionofindia.nic.in/reports.html.

Articles:

• Verma, Ramesh. "The Role of Legislative History in Statutory Interpretation." Journal

of Legal Analysis, vol. 9, no. 3 (2022): 112-130.

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• Chatterjee, Arindam. "Extrinsic Aids in Statutory Interpretation: A Comparative
Analysis." International Journal of Legal Studies, vol. 7, no. 4 (2021): 45-60. Accessed

• Sengupta, Anindita. "The Use of International Treaties in Statutory Interpretation: A

Critical Evaluation." Statutory Interpretation Review, vol. 12, no. 2 (2020):

• Pandey, Mohan. "The Role of Precedents in Interpreting Statutes: A Case Study of

Indian Courts." Indian Journal of Legal Studies, vol. 10, no. 1 (2019): 30-42

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