Facts in the Case
- A statutory provision is capable of two interpretations.
- The first interpretation fully serves the object and purpose of the legislation.
- The second interpretation does not fully serve the legislative purpose.
- The question is: Which interpretation should be preferred?
Issues in the Case
- How to decide between two possible interpretations of a statutory provision?
- Whether courts should prefer the interpretation that best serves the purpose and object of the legislation.
- The role of legislative intent and purposive interpretation in statutory construction.
Principles Applied
1. Purpose or Beneficial Construction Rule
- Courts adopt a purposive or beneficial construction to interpret statutes.
- The chosen interpretation should advance the object and purpose of the legislation.
- An interpretation that frustrates or defeats the purpose of the law is not preferred.
2. Rule of Harmonious and Contextual Interpretation
- Interpretation must be in harmony with the scheme of the statute as a whole.
- The legislative intent, as discerned from the Preamble, object clauses, and context, guides the interpretation.
3. Judicial Precedents
K.K. Verma v. Union of India, AIR 1963 SC 1117
- The Court emphasized interpreting a statute to effectuate its true purpose.
Niyaz Mohammad v. State of UP, AIR 1964 SC 1007
- Interpretation should promote the spirit and objective of the legislation rather than defeat it.
Judgment / Legal Position
- The preferable interpretation is the one that fully serves the object and purpose of the legislation.
- Courts avoid interpretations that produce absurd, unreasonable, or unjust results contrary to legislative intent.
- Purposive interpretation ensures laws are effective, coherent, and meaningful.
