Facts in the Case
- A provision of a penal statute can be interpreted in two different ways.
- The first interpretation results in the conviction of the accused.
- The second interpretation leads to the acquittal of the accused.
- The question arises as to which interpretation the court should prefer.
Issues in the Case
- When a penal provision is ambiguous or capable of two meanings, which interpretation should be adopted?
- Should the court favor the interpretation that results in conviction or acquittal?
- What is the legal principle guiding this choice?
Principles Applied
1. Rule of Strict Construction of Penal Statutes
- Penal laws are strictly construed because they impose penalties and affect personal liberty.
- Ambiguities in criminal statutes must be resolved in favor of the accused.
- This is rooted in the principle “nullum crimen sine lege, nulla poena sine lege” (no crime or punishment without law).
2. The Rule of Lenity
- The rule of lenity directs courts to interpret ambiguous criminal statutes so as to avoid harsh penalties.
- If the language is open to two interpretations, the interpretation favoring the accused (leading to acquittal) should be preferred.
- This protects individuals from arbitrary and excessive punishment.
3. Judicial Precedents
Rambha v. Union of India, AIR 1952 SC 196
- The Supreme Court held that criminal statutes must be interpreted strictly and ambiguities resolved in favor of the accused.
Kedar Nath Singh v. State of Bihar, AIR 1962 SC 955
- The Court emphasized that penal provisions should not be given an interpretation that would unjustly expand their scope.
Judgment / Legal Position
- When faced with two plausible interpretations of a penal provision, courts must adopt the one which is more favorable to the accused.
- This principle safeguards the fundamental right to liberty and upholds the rule of law.
- It also ensures that no person is punished under uncertain or vague laws.