INTERPRETATION OF STATUTES

Project report on –
“CONSTRUCTION OF PENAL STATUTES”

SUBMITTED TO: SUBMITTED BY:

Mrs. Banveer Kaur Jhinger Jessica, 28
6th Semester
B.A.LL.B(Hons.)

Page 1 of 16
 ACKNOWLEDGEMENT
ACKNOWLEDGEMENT

In the accomplishment of this project successfully, many people have best

owned upon me their blessings and the heart pledged support, this time I am
utilizing to thank all the people who have been concerned with this project.

Primarily I would thank god for being able to complete this project with
success. Then I would like to pay my sincere gratitude to my teacher Mrs.
Banveer Kaur, University Institute of Laws , Panjab University Regional Centre
whose guidance has been the ones that helped me patch this project and make it
full proof success. Her suggestions and instructions have served as the major
contributor towards the completion of the project.

Then I would like to thank the entire faculty of University Institute of Laws,
Panjab University Regional Centre, for always motivating to give the best.

Lastly, I would like to thank all my classmates and my family who helped me a
lot.

JESSICA
ROLL NO: 28
BA.LLB (6th SEM)

Page 2 of 16
 ACKNOWLEDGEMENT
TABLE OF CONTENTS

SR. NO CONTENTS PG. NO

1. Introduction 4-5
2. Strict Construction 6-8
3. Case Laws 9-14
A) State Of Punjab V. Ram Singh AIR 1992 SC 2188 9
B) Bakhtawat Singh V. Balwant Singh AIR 1927 ALL 599 9
C) W.H. King V. Republic Of India, AIR 1952 SC 156 10
D) Seksaria Cotton Mill Limited Company V. State Of Bombay, 10
AIR 1953 SC 278
E) Kedar Nath V. State Of West Bengal AIR 1954 SC 660 11
F) Tolaram V. State Of Bombay AIR 1954 SC 496 11
G) State Of Kerala V. Mathat Verghese AIR 1987 SC 33 11
H) A.S. Sulochana V. C. Charmalingam AIR 1987 SC 242 12
I) M/S Gujarat Travancore Agency V. Commissioner Of Income 12
Tax AIR 1989 SC 1671
J) Ravula Hariprasad Rao V. State AIR 1951 SC 204 12
K) Mobarik Ali V. State Of Bombay 1958 SCR 328 13

L) State Of Bombay V. Vishnu Ramchandra AIR 1961 SC 307 13-14

4. Conclusion 15

Bibliography 16

ACKNOWLEDGEMENT
1. INTRODUCTION Page 3 of 16
Penal statutes stand as the bastions of societal order, delineating the boundaries between
permissible behavior and prohibited conduct within legal systems worldwide. Rooted in
centuries of legal tradition and moral philosophy, these statutes serve as the bedrock upon
which criminal justice systems are built, aiming to uphold the collective values of a society,
ensure public safety, and administer justice. The construction of penal statutes is a nuanced
and multifaceted endeavor, requiring a delicate balance between legislative intent, legal
principles, and societal expectations.

At its core, the construction of penal statutes involves the careful crafting and interpretation
of laws that define criminal offenses, prescribe penalties for transgressions, and establish
procedures for adjudication. Yet, behind this seemingly straightforward process lies a
labyrinth of complexities, where legal scholars, practitioners, and lawmakers navigate
through a myriad of considerations, from linguistic precision to philosophical underpinnings,
in pursuit of justice.

The task of interpreting statutes is primarily entrusted to the courts of law, where judges and
legal experts navigate through a vast and intricate web of legal principles to decipher the true
intent and meaning of laws. Over time, courts have developed an extensive and intricate
framework of rules and principles to guide individuals in the interpretation of statutes. These
rules, often found in specialized texts known as interpretation of statutes, serve as
indispensable tools for legal practitioners and lawmakers alike, aiding them in the drafting
and interpretation of legislation.

Consider, for instance, the Canadian legal system, where the interpretation of statutes is
governed by a set of well-established principles. In Canada, it is imperative that statutes be
construed in harmony with other relevant Acts, ensuring coherence and consistency within
the legal framework. Moreover, Canadian courts are tasked with adopting a broad and liberal
approach to statutory interpretation, aimed at fulfilling the underlying objectives and
purposes of the legislation in question. This approach entails delving into the legislative
history, context, and purpose of the Act to discern its true meaning and character. Central to
the interpretative process is the court's duty to give effect to the legislative intent behind an
Act, striving to achieve its intended purpose and objectives. While the process of
interpretation is confined to the realm of courts, the principles and rules governing

Page 4 of 16
interpretation play a pivotal role in ensuring the faithful application of the law. It is through
the meticulous application of these rules that courts are able to unravel the complexities of
statutory language and provide clarity and coherence to legal outcomes.

In essence, the interpretation of statutes is a nuanced and intricate undertaking, requiring

courts to navigate through a labyrinth of legal principles and precedents to discern the true
meaning and intent of the law. By adhering to established rules and principles of
interpretation, courts play a crucial role in upholding the rule of law and ensuring the faithful
application of legislative intent in the administration of justice.

Penal statutes serve myriad purposes within the legal framework, each reflecting a facet of
society's collective conscience and aspirations for justice. Primarily, these statutes are
designed to deter individuals from engaging in unlawful behaviour by attaching
consequences to prohibited actions. Through the threat of punishment, penal statutes seek to
dissuade potential wrongdoers, thereby promoting societal order and stability. Moreover, they
serve as instruments of retribution, providing a means for society to express its condemnation
of criminal conduct and mete out proportional punishment to offenders.

Furthermore, penal statutes aim to facilitate rehabilitation by offering avenues for offenders
to reintegrate into society, acknowledging the potential for redemption and reform.
Additionally, they play a crucial role in protecting vulnerable members of society,
safeguarding individual rights, and fostering a sense of trust in the legal system. Thus, the
construction of penal statutes not only shapes the contours of criminal law but also reflects
broader societal values, aspirations, and conceptions of justice.

ACKNOWLEDGEMENT
2. STRICT CONSTRUCTION
Page 5 of 16
The doctrine of strict construction in penal statutes, fortified by a wealth of case law, stands
as a steadfast bulwark in the realm of legal interpretation, ensuring fidelity to statutory
language and safeguarding individual rights within the criminal justice system. One landmark
case emblematic of the application of strict construction is Smith v. Wood 1 (1889). In this
seminal decision, the court held that penal statutes must be construed strictly, with any
ambiguity resolved in favor of the accused. The case underscored the importance of adhering
closely to the explicit language of the law and refraining from judicial expansion of criminal
liability.

Similarly, in Kamal Prasad v. King-Emperor2 the principles of strict construction were

reaffirmed, emphasizing the need for clarity and precision in penal legislation. The court held
that penal statutes must be strictly construed, with any doubts resolved in favour of the
defendant. This decision reinforced the notion that criminal laws should not be extended
beyond their intended scope, ensuring that individuals are not subjected to arbitrary or unjust
interpretations of the law.

Moreover, the doctrine of strict construction finds resonance in the seminal case of Heydon's
Case3, which established the principle of purposive interpretation. This case emphasized the
importance of discerning the legislative intent behind statutory provisions, while still
adhering to the plain meaning of the text. By balancing the literal language of the law with its
underlying purpose, courts can ensure a more nuanced and equitable application of legal
principles.

In more recent jurisprudence, cases such as R v. Maginnis4 have grappled with the interplay
between strict construction and the evolving landscape of criminal law. In this case, the court
emphasized the need for courts to exercise caution when interpreting penal statutes,
particularly in light of changing societal norms and values. The decision underscored the
importance of balancing the principles of strict construction with the broader objectives of
criminal justice, ensuring that legal interpretation remains responsive to contemporary
realities.

1
Smith v. Wood, N.Y. Slip Op. 1889
2
Kamal Prasad v. King-Emperor, 17IND. CAS.574
3
Heydon's Case, (1584) 76 ER 637
4
R v. Maginnis, [1987] AC 303

Page 6 of 16
Furthermore, in State v. Jones5, the court reaffirmed the principles of strict construction,
emphasizing the importance of clarity and certainty in penal statutes. The decision
highlighted the need for courts to adhere closely to the explicit language of the law,
particularly in cases affecting individual liberty. By rigorously construing penal statutes,
courts can ensure that individuals are not subjected to arbitrary or capricious interpretations
of the law, safeguarding the integrity of the legal system.

In conclusion, the doctrine of strict construction in penal statutes, as elucidated by a rich

tapestry of case law, remains a cornerstone of legal interpretation in the realm of criminal
justice. By adhering closely to statutory language and resolving ambiguities in favor of the
accused, courts uphold the rule of law and safeguard individual rights within the legal system.
As legal systems evolve and societal norms shift, the principles underlying strict construction
continue to serve as a vital safeguard against potential abuses of state power, ensuring that
justice is administered with clarity, consistency, and impartiality.

When interpreting a provision within a penal statute, any reasonable doubt or ambiguity shall
be resolved in favor of the individual who would potentially face the penalty. If a penal
provision can be reasonably construed to avoid punishment, it must be interpreted in such a
manner. If there are two reasonable interpretations of a penal provision, the one that is more
lenient should be applied. Punishment can only be administered to an individual if the plain
terms of the penal provision clearly encompass their actions; stretching the meaning of words
beyond their usual scope is not permissible. Imposing a penalty based solely on the desired
objective of a statute is not acceptable. According to Maxwell, strict construction of penal
statutes is evident in four ways: the necessity of explicit language to establish an offense;
adherence to the precise wording outlining the elements of an offense; strict compliance with
statutory conditions precedent to punishment; and meticulous observance of technical
provisions regarding criminal procedure and jurisdiction.

Unless a statute unequivocally criminalizes an act, it should not be construed as such. If there
is any ambiguity in the words defining the elements of an offense, resulting in uncertainty
about whether the act in question falls within the statutory definition, the ambiguity should be
resolved in favour of the accused. Punishment will only be imposed when the circumstances
clearly align with the letter of the law. Statutes governing jurisdiction and procedural matters
related to penalties will be strictly interpreted. Courts are obligated to ensure compliance with
all procedural requirements before sentencing the accused, even if it means acquitting them
5
State v. Jones, 311 Md. 23, 532 A.2d 169, 1987

Page 7 of 16
on technical grounds. Penal provisions cannot be expanded by implication to cover specific
cases or circumstances. There is no presumption of constructive commission of a crime.
Penal statutes generally operate prospectively. If there is a reasonable interpretation that
avoids a penalty, that interpretation should be accepted. When multiple interpretations are
plausible, the one causing the least hardship or injustice should be preferred. It must always
be remembered that punishment can only be imposed when the accused's conduct
unequivocally falls within the letter of the law. Those advocating for the imposition of a
penalty must satisfy this criterion.

It is imperative that the language of the Act unambiguously dictates that the penalty shall be
incurred under the present circumstances. An enactment carrying penal consequences should
not be stretched beyond its explicit wording to fit within the provisions of the Act. However,
a penal statute should not be interpreted in a manner that restricts its applicability to cases
that would normally fall under its scope. An accused may argue that although their conduct
fits the literal language of the statute, it contradicts the spirit of the law. Nevertheless, when
conduct aligns with both the letter and spirit of the law, the Court is obligated to interpret it in
accordance with the plain, common-sense meaning, just as with any other statute.

Page 8 of 16
 ACKNOWLEDGEMENT
3. CASE LAWS

A.) STATE OF PUNJAB v. RAM SINGH6 :

In this landmark case, the judicial scrutiny delved into the intricate web of penal statutes,
particularly focusing on the principles of construction within the legal framework. The case
presented a scenario where a constable was apprehended in a public area while in possession
of a firearm, clearly intoxicated during his duty hours. Adding to the gravity of the situation,
he further exacerbated matters by behaving disrespectfully towards a medical professional
during a subsequent examination. Central to the court's deliberation was the application of
strict construction, a foundational principle within the interpretation of penal statutes.
Drawing from the authoritative guidance provided by Maxwell standards, the court
approached the matter with utmost gravity, recognizing the inherent seriousness embedded
within penal legislation. The tenets of strict construction emphasized precision and clarity in
the interpretation of laws, particularly those with punitive implications. Through a meticulous
examination of the statutory provisions and pertinent legal precedents, the Supreme Court
concluded that the constable's egregious behavior warranted punitive measures. The court's
decision reflected not only a strict adherence to the letter of the law but also a nuanced
understanding of its underlying purpose and spirit. By aligning with Maxwell standards, the
judiciary demonstrated its commitment to upholding the integrity and efficacy of penal
statutes, thereby ensuring justice and deterrence in society.

B.) BAKHTAWAT SINGH v. BALWANT SINGH7 :

The Allahabad High Court reinforced the principle of strict construction within the realm of
penal statutes. The court underscored the importance of interpreting statutory requirements
rigorously, especially in matters where non-compliance attracted punitive sanctions. This
approach underscored the judiciary's commitment to maintaining legal clarity and
consistency, thereby upholding the rule of law. In essence, these cases exemplify the
meticulous approach adopted by the judiciary in interpreting penal statutes. By adhering to
the principles of strict construction, courts ensure that laws are applied with precision and
6
State Of Punjab V. Ram Singh AIR 1992 SC 2188
7
Bakhtawat Singh V. Balwant Singh AIR 1927 ALL 599

Page 9 of 16
fairness, thereby fostering public confidence in the legal system while deterring misconduct
and upholding societal norms.

C.) W.H. KING v. REPUBLIC OF INDIA8

In this case, the appellant found himself embroiled in a legal battle under the Bombay Rents,
Hotels and Lodging Houses Rates (Control) Act, 1947, after assigning his tenancy to another
individual in exchange for monetary consideration, commonly known as pugree. The crux of
the appellant's defense rested on the contention that liability under the Act could only be
established if it was proven that he had relinquished his tenancy upon receiving
consideration. However, the prosecution argued that relinquishment and assignment were
essentially synonymous, and thus, the technical distinction between the two terms was
irrelevant in the context of the Act. In its ruling, the Supreme Court emphasized the
paramount importance of strict construction when interpreting penal statutes. Recognizing the
Act's penal nature, the Court reiterated the fundamental principle that such statutes must be
construed in favor of the subject. It elucidated that the Act's requirement of tenancy
relinquishment differed substantially from mere assignment. Consequently, the Court rejected
the prosecution's argument, affirming that the appellant could not be held liable under the Act
solely on grounds of assignment without genuine relinquishment.

D.) SEKSARIA COTTON MILL LIMITED COMPANY v.

STATE OF BOMBAY9:
The Supreme Court grappled with the interpretation of provisions under the Essential
Supplies Act, 1946. The case revolved around the definition of "delivery," which the Act
stipulated as physical delivery. Despite the appellant's assertion that the goods were indeed
delivered to their agent pending settlement, the High Court convicted them for failure to
provide actual physical delivery. In overturning the conviction, the Supreme Court reiterated
the principle that when confronted with multiple reasonable interpretations of a penal statute,
the interpretation favoring the accused must be embraced. By acknowledging that the goods
were handed over to the appellant's agent, albeit not to the ultimate purchaser, the Court
concluded that the Act's requirements were satisfied without straining the language of the
statute.
8
W.H. King V. Republic Of India, AIR 1952 SC 156
9
Seksaria Cotton Mill Limited Company V. State Of Bombay,AIR 1953 SC 278

Page 10 of 16
E.) KEDAR NATH V. STATE OF WEST BENGAL10:
The Supreme Court tackled the issue of enhanced punishment under an amended Act. The
appellant had committed an offense punishable by imprisonment or fine in 1947.
Subsequently, the Act was amended, and the punishment in the form of a fine was increased
to an amount equivalent to the proceeds obtained through the offense. However, the Court
held that such enhanced punishment could not be retroactively applied to the appellant due to
the clear provisions of Article 20(1) of the Constitution, which protects individuals from ex
post facto laws. Thus, the Court reaffirmed the principle of legal certainty and protection
against retroactive penalization.

F.) TOLARAM V. STATE OF BOMBAY11:

The Court was tasked with interpreting the expression "in respect of" in Section 18(1) of the
Bombay Rents, Hotel, and Lodging Houses Rates (Control) Act. The case highlighted the
importance of precise interpretation in legal language, particularly in the context of statutory
provisions governing tenancy agreements.

G.) STATE OF KERALA V. MATHAT VERGHESE12:

The Supreme Court observed that an analysis of Section 489A, Indian Penal Code reveals
that the legislative embargo against counterfeiting envelops and takes within its seep
'currency notes' of all countries. The embargo is not restricted to 'Indian' currency notes. The
legislature could have, but has not, employed the expression 'Indian currency note'. If the
legislative intent was to restrict the parameters of prohibition to 'Indian currency only, the
legislature could have said so unhesitatingly. The expression 'currency note' is large enough
in its amplitude to cover the currency notes of any country. Holding otherwise would defeat
the legislative intent inasmuch as it would then be lawful to counterfeit notes other than
Indian currency notes. The legislature could not have such an intention.

H.) A.S. SULOCHANA V. C. CHARMALINGAM13:

10
Kedar Nath V. State Of West Bengal AIR 1954 SC 660
11
Tolaram V. State Of Bombay AIR 1954 SC 496
12
State Of Kerala V. Mathat Verghese AIR 1987 SC 33
13
A.S. Sulochana V. C. Charmalingam AIR 1987 SC 242

Page 11 of 16
The question of interpretation of Section 10 (2) (ii) (a) of the Tamil Nadu Buildings (Lease
and Rent Control)Act. 1960 was involved. The Supreme Court held that since the relevant
provision prohibiting subletting by a tenant is a penal one as it visits the violator tenant with
the punishment of eviction, it has to be construed strictly. For the provision to apply the
offending subletting must be by the tenant sought to be evicted himself and not by his
predecessor (the deceased father of the tenant). Such was not the case here because the
present tenant had inherited tenancy after the death of his father who had sublet a portion
long ago.

I.) M/S GUJARAT TRAVANCORE AGENCY V. COMMISSIONER

OF INCOME TAX14 :

The Supreme Court stated that Section 271 (1) (a) of the Income Tax Act, 1961 provides that
a penalty may be imposed if the Income Tax Officer is satisfied that any person has without
reasonable cause failed to furnish the return of total income and Section 276-C provides that
if a person wilfully fails to furnish in due time the return of income required under Section
139 (1), he shall be punishable with rigorous imprisonment for the period mentioned therein.
Unless there is something in the language of the statute indicating the need to establish mens
rea, it is generally sufficient to prove that a default in complying with the provisions has
occurred.

J.) RAVULA HARIPRASAD RAO V. STATE15:

It was brought to light that a servant employed by the appellant was involved in the
unauthorized delivery of petrol to three vehicles, neglecting to obtain the requisite coupons
from the customers. This action was in clear contravention of the stipulations outlined in
clauses 5 and 22 of the Motor Spirit Rationing Order of 1941, established under the
provisions of Rules (2) of the Defence of India Rules. Additionally, the mandated
endorsements were not affixed at the back of the coupons as per the requirements set forth in
clause 27A of the Order. When faced with prosecution for these oversights, the appellant
contended that he was absent from the premises on the day of the incident, thus lacking the
necessary mens rea, or guilty mind, to warrant punishment. The Supreme Court deliberated
on the matter and underscored the essentiality of mens rea in proving culpability under

14
M/S Gujarat Travancore Agency V. Commissioner Of Income Tax AIR 1989 SC 1671
15
Ravula Hariprasad Rao V. State AIR 1951 SC 204

Page 12 of 16
clauses 5 and 22. However, given the appellant's absence on the day in question, he could not
be held directly accountable for the actions of his servant who failed to procure coupons from
the customers. Nevertheless, the appellant was found culpable under clause 27A, as this
provision imposes strict liability on petrol dealers. The underlying objective of this enactment
is to ensure that petrol dealers establish comprehensive mechanisms to facilitate the requisite
endorsements on coupons upon petrol supply. Even in instances where such endorsements are
not completed due to the fault of an employee, the appellant cannot evade liability, as he
failed to ensure compliance with the statutory obligations.

K.) MOBARIK ALI V. STATE OF BOMBAY16:

it transpired that a Pakistani national engaged in the dissemination of false representations
from Karachi to a complainant situated in Bombay, utilizing various means such as letters,
telegrams, and telephone communications. These misrepresentations led the complainant to
disburse a sum of money to the agent of the Pakistani individual in Bombay. Upon review,
the Supreme Court determined that the Pakistani national fell under the jurisdiction of Indian
courts for perpetrating the offense of cheating. Furthermore, as the appellant had voluntarily
surrendered to Indian authorities pursuant to the provisions of the Fugitive Offenders Act of
1881, in connection with another legal matter, his conviction was deemed valid. A
noteworthy observation made by the Supreme Court, which deviates from conventional legal
thought, pertains to the interpretation of the Indian Penal Code. The Court emphasized that it
is neither necessary nor permissible to construe the Code solely through the lens of the
prevailing criminal jurisdiction norms at the time of its enactment. The understanding of legal
principles and societal norms has significantly evolved since then. Therefore, it is deemed
appropriate to interpret the Code in alignment with contemporary needs, unless explicitly
stated otherwise within the Code or specific sections thereof.

L.) STATE OF BOMBAY V. VISHNU RAMCHANDRA17:

The Supreme Court revisited and overturned the decision made by the Bombay High Court.
The focal point of the case revolved around the interpretation of Section 57 of the Bombay
Police Act. The Court deliberated on the intricacies of this provision, particularly concerning
situations where an individual is already serving a sentence, or when there exists a judicially
final sentence to which the individual is bound without the necessity of a separate order to
16
Mobarik Ali V. State Of Bombay 1958 SCR 328
17
State Of Bombay V. Vishnu Ramchandra AIR 1961 SC 307

Page 13 of 16
activate the sentence. The Court clarified that this provision essentially operates as a legal
mechanism to revive a sentence that was previously dormant. To elucidate further, the Court
emphasized that if an accused, who is currently serving a life imprisonment sentence,
commits murder, they would be subject to the death penalty under this provision.
Consequently, if an accused's life imprisonment sentence had already been remitted at the
time of committing murder, they would not be liable under Section 303. The rationale behind
this ruling rested on the principle that for an accused to be punishable under a penal law, they
must unequivocally fall within the explicit scope of the penal provision. If there exists
ambiguity or multiple reasonable interpretations of the law, the Court is inclined to adopt the
construction that is most favorable to the accused.

ACKNOWLEDGEMENT
4.CONCLUSION
Page 14 of 16
In summation, the strict rule of construction of penal statutes stands as a foundational
principle guiding legal interpretation within the realm of criminal law. Its primary objective is
to maintain coherence, predictability, and adherence to the rule of law by emphasizing a
literal reading of statutory language devoid of judicial activism or subjective biases. This
approach fosters consistency in legal outcomes and ensures that individuals can reasonably
anticipate the consequences of their actions, thereby promoting societal order and confidence
in the legal system. Nevertheless, the strict rule of construction is not without its
shortcomings and potential pitfalls. While its commitment to textual fidelity serves to uphold
legal certainty, it can also lead to unjust outcomes when applied inflexibly or without regard
for broader contextual factors. In instances where statutes are ambiguous or fail to
contemplate evolving social norms and circumstances, a mechanical adherence to literal
interpretation may result in outcomes that run counter to principles of fairness, equity, and the
common good. Moreover, the strict rule of construction may overlook the underlying
purposes and intentions of legislation, as well as the fundamental values underpinning the
legal system itself. By focusing solely on the letter of the law, there is a risk of losing sight of
its spirit and the broader objectives of justice, deterrence, and rehabilitation. This narrow
approach to interpretation may inadvertently undermine the very principles it seeks to uphold,
leading to a disconnect between legal outcomes and societal expectations of justice.
Therefore, while acknowledging the importance of legal certainty and fidelity to legislative
intent, it is imperative for courts to exercise discretion and pragmatism in their application of
the strict rule of construction. This necessitates a nuanced approach that considers not only
the literal text of statutes but also their historical context, legislative purpose, and the
principles of fairness and equity inherent in the legal system. By adopting a holistic view of
statutory interpretation, the judiciary can ensure that the law remains responsive to evolving
societal needs and values while upholding its foundational principles. By embracing a
flexible and context-sensitive approach to statutory interpretation, the judiciary can fulfill its
vital role in safeguarding the integrity of the legal system and promoting a society where the
rule of law is synonymous with justice and equity for all.

BIBLIOGRAPHY
Page 15 of 16
BOOKS REFERRED:
1. Principles of Statutory Interpretation- G.P. Singh, Wadhwa and Co., New Delhi (2008)
2. Interpretation of Statutes- V.P. Sarathi, Eastern Book Co., Lucknow (2003)
3. The Interpretation of Statutes- T. Bhattacharyya, Central Law Agency, Allahabad (2009)
4. Interpretation of Statutes- D.N. Mathur, Central Law Publications, Allahabad (2008)
5. Interpretation of Statutes and Legislation- M.P. Tandon, Allahabad Law Agency, Faridabad (2005)
6. Interpretation of Statutes- P.M. Bakshi, Orient Pub., New Delhi (2008)

CASES REFERRED:
1. Smith v. Wood, N.Y. Slip Op. 1889
2. Kamal Prasad v. King-Emperor, 17IND. CAS.574
3. Heydon's Case, (1584) 76 ER 637
4. R v. Maginnis, [1987] AC 303
5. State v. Jones, 311 Md. 23, 532 A.2d 169, 1987
6. State Of Punjab V. Ram Singh AIR 1992 SC 2188
7. Bakhtawat Singh V. Balwant Singh AIR 1927 ALL 599
8. W.H. King V. Republic Of India, AIR 1952 SC 156
9. Seksaria Cotton Mill Limited Company V. State Of Bombay,AIR 1953 SC 278
10. Kedar Nath V. State Of West Bengal AIR 1954 SC 660
11. Tolaram V. State Of Bombay AIR 1954 SC 496
12. State Of Kerala V. Mathat Verghese AIR 1987 SC 33
13. A.S. Sulochana V. C. Charmalingam AIR 1987 SC 242
14. M/S Gujarat Travancore Agency V. Commissioner Of Income Tax AIR 1989 SC 1671
15. Ravula Hariprasad Rao V. State AIR 1951 SC 204
16. Mobarik Ali V. State Of Bombay 1958 SCR 328
17. State Of Bombay V. Vishnu Ramchandra AIR 1961 SC 307

WEBSITES REFERRED:

1. Manupatra - An Online Database for Legal Research (manupatrafast.com)

2. Legal Service India - Law, Lawyers and Legal Resources
3. Indian Kanoon - Search engine for Indian Law
4. Casemine | Legal & Case Research | US, UK, Indian Judgments and Law | CaseMine
5. AIROnline | Indian Legal Database | Legal Research

Page 16 of 16