The Golden Rule of interpretation is a modification of the Literal Rule. It begins by applying the ordinary grammatical meaning of the statutory words, just like the Literal Rule, but allows courts to depart from this literal meaning to avoid absurdity, inconsistency, hardship, or injustice. The Golden Rule thus serves as a safeguard, permitting judicial correction in cases where a strict application of literal meaning would defeat the purpose of the statute or produce illogical or unacceptable results.
This rule recognizes that although legislative language is the primary guide, the intent of the legislature must prevail when the literal words lead to anomalies or contradictions.
Two Forms of the Golden Rule
There are two recognized forms of the Golden Rule:
- Narrow Approach: When a word has more than one meaning, the court may choose the meaning that avoids absurdity.
- Wider Approach: Even when words have only one meaning, but applying them would lead to a manifestly absurd result, the court may depart from the literal rule to avoid injustice.
Judicial Basis
- Becke v. Smith (1836): The Golden Rule was invoked by stating that the words must be taken in their ordinary sense, “unless it would lead to some absurdity.”
- Grey v. Pearson (1857): Lord Wensleydale stated that words should be taken in their ordinary sense unless it would lead to inconsistency or absurdity.
- State of Madhya Pradesh v. Azad Bharat Financial Co. (1967): The Indian Supreme Court applied the Golden Rule to ensure a harmonious interpretation that did not defeat the object of the law.
Illustration
Suppose a statute states, “A man shall not marry his wife’s sister while she is alive.” If interpreted literally, this would mean he could marry her sister after his wife dies, which clearly defeats the moral and social objective behind the law. Applying the Golden Rule, the court would interpret the law to mean that marriage with the wife’s sister is altogether prohibited during the lifetime of the wife, thus avoiding the absurdity.
Purpose of the Golden Rule
The Golden Rule is used when:
- Literal interpretation leads to absurd or anomalous results.
- Strict meaning would defeat the true intent of the legislature.
- The law, if applied literally, would result in injustice or impracticality.
Limitations
- It cannot be used to rewrite legislation or create a new meaning that was not intended by Parliament.
- It applies only when literal interpretation fails or produces contradictions.
- It requires the presence of a clear absurdity or injustice, not just an inconvenient result.
Code to Remember the Answer – FAIR
| Letter | Stands For | Explanation |
|---|---|---|
| F | Fixes Absurdity | The rule is applied to fix absurd or illogical results from literal meaning. |
| A | Avoids Injustice | Used to prevent unjust consequences of strict application. |
| I | Interprets Flexibly | Allows a limited departure from the literal meaning to uphold intent. |
| R | Respects Legislative Intent | Ensures that the purpose of the law is not defeated by rigid interpretation. |
