Facts in the Case
- The case concerns the interpretation of a protective legislation, specifically the Consumer Protection Act.
- The language of a provision in the Act is ambiguous and capable of two interpretations.
- One interpretation would result in the grant of remedy to consumers.
- The other would result in denial of such remedy.
- The issue is which interpretation should be adopted when the law is beneficial or welfare-oriented in nature.
Issues in the Case
- When a beneficial legislation like the Consumer Protection Act allows for two possible interpretations, which one should the court prefer?
- Should the court give a narrow and restrictive interpretation or a liberal and purposive interpretation to achieve the objectives of the Act?
Principles Applied
1. Beneficial Construction (Liberal Interpretation)
- Protective or welfare statutes are interpreted using the principle of beneficial construction.
- The primary objective is to advance the purpose of the legislation—in this case, protecting the interests of consumers.
2. Rule of Purposive Interpretation
- When statutory language is capable of multiple meanings, the court must adopt the interpretation that furthers the purpose of the statute.
- The goal is to secure the intended benefits for the protected class (here, consumers), rather than defeating it through technicalities.
3. Presumption in Favour of the Beneficiary
- In the case of beneficial or remedial legislation, any ambiguity must be resolved in a way that favors the beneficiaries—the consumers.
- Courts presume that the legislature intended to promote justice, fairness, and protection for the class the law aims to safeguard.
4. Judicial Precedents
- In Lucknow Development Authority v. M.K. Gupta, AIR 1994 SC 787, the Supreme Court held that the Consumer Protection Act must be construed liberally to promote and protect consumer rights.
- In Sundarbhai Ambalal Desai v. State of Gujarat, the Court emphasized that social justice legislation should not be interpreted narrowly to defeat its purpose.
Judgment
- When a protective statute such as the Consumer Protection Act is open to two interpretations, the court should adopt the one that favors granting remedy to consumers.
- This approach ensures that the object of the legislation is fulfilled and access to justice is widened.
- A liberal and purposive interpretation is essential to give full effect to the legislative intent behind such welfare laws.
