Facts in the Case
- An Act and its Rules were drafted simultaneously by the same drafting team.
- Both the Act and Rules were published in the Official Gazette on the same day.
- The Act is of such a nature that it cannot operate effectively without the Rules.
- The question arises whether the Rules can be used as aids in interpreting the provisions of the Act.
Issues in the Case
- Can Rules, made under the authority of the Act and published simultaneously, be used as a tool for interpreting the Act?
- What is the legal position on the relationship between an Act and its subordinate Rules in interpretation?
- Do such Rules have any evidentiary or interpretative value in understanding the legislative intent?
Principles Applied
1. Rules as Aids to Interpretation
- Rules and regulations framed under an Act are delegated legislation intended to carry out the objects of the Act.
- When the Act cannot be effectively enforced or operated without the Rules, these Rules serve as a valuable tool to understand the scope and purpose of the Act.
- Courts often refer to Rules, notifications, and subordinate legislation to clarify ambiguities or technical details in the parent Act.
2. Simultaneous Publication and Common Intent
- When an Act and its Rules are drafted and published simultaneously, it indicates a unified legislative intent.
- Such contemporaneous legislation supports the view that the Rules reflect the spirit and purpose of the Act.
- Hence, Rules can be used to interpret and give effect to the provisions of the Act.
3. Judicial Precedents
CIT v. Samsons (1986) 2 SCC 270
- The Supreme Court held that Rules framed under an Act can be used as interpretative aids especially when the Act is silent or ambiguous on certain points.
Union of India v. Angul Electricity Co. Ltd., AIR 1967 SC 1164
- The Court observed that Rules are a part of the legislative scheme and should be considered in construing the Act.
Judgment / Legal Position
- The Rules published simultaneously with the Act can be taken as helpful tools to interpret and understand the Act’s provisions.
- They assist in clarifying ambiguities, filling procedural gaps, and giving effect to the legislative intent.
- However, Rules cannot override or contradict the clear language of the Act.
- They are subsidiary legislation and derive their authority from the parent Act.
