Facts in the Case
- A penal provision under a statute is found to be ambiguous and capable of two interpretations.
- Under the first interpretation, the language of the statute would lead to the conviction of the accused.
- Under the second interpretation, the provision could be construed in a way that would lead to the acquittal of the accused.
- The issue arises on which interpretation should be preferred when both are legally plausible.
Issues in the Case
- When a penal statute admits two interpretations, one leading to guilt and the other to innocence, which one should the court adopt?
- What principle of statutory interpretation governs the resolution of such ambiguity in penal provisions?
- Should the rule of lenity be applied in such circumstances?
Principles Applied
1. Rule of Strict Construction of Penal Statutes
- Penal statutes must be strictly construed.
- If the language of a penal law is vague, unclear, or ambiguous, courts must not extend its scope through interpretation.
- Any ambiguity must be resolved in favor of the accused.
2. Rule of Lenity
- Known as the benefit of ambiguity in criminal law, this rule states that where two reasonable interpretations exist, the interpretation favorable to the accused must be preferred.
- The principle is grounded in the idea that no one should be punished under a law unless it is clear what conduct is prohibited.
3. Presumption Against Retrospective Criminal Liability
- Courts presume that criminal laws are not to be interpreted expansively or retrospectively.
- Where doubt exists, courts avoid imposing penal consequences, unless the statute clearly mandates it.
4. Judicial Precedents
- In Tolaram Relumal v. State of Bombay, AIR 1954 SC 496, the Supreme Court held that if the provision is reasonably capable of two interpretations, the one which favors the accused must be adopted.
- In State of Madhya Pradesh v. Azad Bharat Financial Co., (1967) AIR 276, the Court reiterated that criminal liability must be imposed only when the language of the statute is clear and unambiguous.
Judgment
- In cases of doubt or ambiguity in a penal provision, the interpretation that leads to acquittal of the accused must be preferred.
- This approach is consistent with the constitutional principles of fair trial and liberty.
- Courts must ensure that citizens are not punished unless the law clearly prohibits their conduct.
