Facts in the Case
- A conflict arises between a provision of substantive law and a provision of procedural law.
- Substantive law defines rights, duties, and liabilities of individuals (e.g., criminal law, contract law, tort law).
- Procedural law governs the methods and processes used to enforce those rights and obligations (e.g., Civil Procedure Code, Criminal Procedure Code).
- The dispute concerns which provision should prevail when a substantive right is affected or limited by a conflicting procedural rule.
Issues in the Case
- In case of a conflict between a rule of substantive law and a rule of procedural law, which one should take precedence?
- What is the appropriate rule of interpretation to resolve such a conflict?
- Should procedural rules override established substantive rights, or vice versa?
Principles Applied
- Doctrine of Primacy of Substantive Law
- Substantive law deals with fundamental rights, duties, and liabilities.
- Procedural law is intended to facilitate the enforcement of those rights—not to defeat or override them.
- Courts have held that procedural law is the handmaid of justice and cannot destroy substantive rights.
- Interpretation Favouring Substantive Rights
- Where two laws conflict, and one affects a substantive right, courts generally adopt an interpretation that preserves the right unless clearly excluded by statute.
- This is particularly important in penal and civil liability contexts, where individual liberties and rights are at stake.
- Judicial Precedents
- State of Uttar Pradesh v. Mohammad Naim, AIR 1964 SC 703: The Supreme Court held that procedural provisions should not be interpreted to curtail substantive rights unless the legislature clearly intended to do so.
- Union of India v. Mohd. Nazim, AIR 1980 SC 431: The Court reiterated that procedure must yield to substantive law when the two are in direct conflict.
- Sangram Singh v. Election Tribunal, AIR 1955 SC 425: The Court emphasized that procedural law is not an end in itself, but a means to achieve justice.
- Purposive Interpretation is Preferable
- To resolve the conflict, courts must adopt a purposive or harmonious interpretation.
- The goal is to interpret procedural provisions in a way that supports and facilitates substantive rights and does not render them ineffective.
- If a procedural rule is capable of two interpretations, the one that preserves the substantive right is preferred.
Judgment
- In the event of a conflict, substantive law prevails over procedural law.
- Procedural law must be interpreted in a manner that supports the enforcement of substantive rights, not in a way that defeats or nullifies them.
- Purposive and harmonious interpretation is the correct approach to maintain the balance between form and substance.
- Only where the legislature has explicitly and unambiguously overridden substantive law through a procedural provision can such a procedure be upheld.