A protective legislation like the Consumer Protection Act is capable of two possible interpretations. One interpretation would result in granting remedy to consumers. The other interpretation would result in denial of remedy to consumers. Which one is preferable? Give reasons.

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.

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