INTERPRETATION OF STATUTE

ON
EXTERNAL RULES OF
INTERPRETATION

SUBMITTED TO: SUBMITTED BY:

PROF. MOHM. USMAN MD AHMAR MATIN

BA.LLB (Hons.)

3rd year (6th semester)

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 ACKNOWLEDGEMENT

First and foremost, I would like to thank our subject teacher Prof. MOHD. USMAN sir, for
the valuable guidance and advice. He inspired us greatly to work on this interesting
assignment. His willingness to motivate us contributed tremendously to our assignment. I
also would like to thank him for showing us some sample assignments on how to go about
the research assignment. It gave me an opportunity to analyse and learn about the operation
of various Articles of Constitution of India relating to the topic. Besides, I would like to thank
the Faculty staff for providing us with a good environment and facilities for completing this
assignment. In addition, I would also like to thank my seniors who provided me with the
valuable information acting as a source of guidance in making the assignment. Finally, an
honourable mention goes to my family and friends for their understandings and supports in
completing this assignment. Without the help of the particulars mentioned above, making of
this assignment would not have been possible.

MD AHMAR MATIN

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 TABLE OF CONTENT

• INTRODUCTION………………………………………………….....…………….. 4

• DICTIONARY…………………………………….……….………..………….…… 5

• HISTORICAL BACKGROUND…………………….………………………..…… 6

• TEXT BOOKS………………………………………………..………………………8

• STATEMENT OF OBJECT AND REASONS………………….…….……………9

• PRECEDENTS……………………………………………..….……………………..9

• FOREIGN DECISION……………………………………………….…………….14

• CONCLUSION…………………………………….……………………..…………15

• BIBLIOGRAPHY…………………………………….………..………..………….16

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 INTRODUCTION
They are the Statement of Objects and Reasons when the Bill was presented to Parliament,
the reports of the Committee, if any, preceded the Bill, legislative history, other statutes in
pari material and legislation in other States which pertain to the same subject matter, persons,
things or relations.
The history of legislation, the enactments which are repealed, the parliamentary debates,
dictionary commentaries etc. are external aids to construction. It is important to point out here
that the legislature adopts the device of making a statute by “reference” and by
“incorporation”. When the statute is incorporated in another statue by the legislature, the
incorporated statute or statute referred to therein is external aid for interpreting the statute in
question. There has been a controversy in India regarding the use of parliamentary debates
for interpreting the Constitution. It is now settled that the court can always refer to the
debates in the legislature while interpreting the statute to know the intention if there is a
doubt about the provision. More often than not, a provision is introduced in the Bill and after
some debate either it is altered or modified or amended before finally it receives the assent of
the President. Such external aids are helpful in interpreting the law.

Where the Legislature has not chosen to define the expression the court of law have,
therefore, to fall back upon other aids for finding the intention of the Legislature; for example
by reference to the context and object and purpose of the legislative measure in question. The
court may further have resort to dictionaries and judicial interpretation of this award as used
in other statutes; but it cannot be denied that these methods are not as satisfactory as a precise
and clear legislative definition in the statute itself.

In B. Prabhakar Rao v. State of Andhra Pradesh1, the observations quoted below, are
illuminating:-
"Where internal aids are not forthcoming, we can always have recourse to external aids to
discover the object of the legislation. External aids are not ruled out. This is now a well
settled principle of modern statutory construction. Thus 'Enacting History' is relevant: "The
enacting history of an Act is the surrounding corpus of public knowledge relative to its
introduction into Parliament as a Bill, and subsequent progress through, and ultimate passing
by, Parliament. In particular it is the extrinsic material assumed to be within the

1
1985 Suppl (2) SCR 573.

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contemplation of Parliament when it passed the Act." Again "In the period immediately
following its enactment, the history of how enactment is regarded in the light of development
from time to time." "Official statements by the government department administering an Act,
or by any other authority concerned with the Act, may be taken into account as persuasive
authority on the meaning of its provisions." Justice may be blind but it is not to be deaf.
Judges are not to sit in sound proof rooms.
Committee reports, Parliamentary debates, Policy statements and public utterances of official
spokesmen are of relevance in statutory interpretation. But 'the comity, the courtesy and
respect that ought to prevail between the two prime organs of the State, the legislature and the
judiciary', require the courts to make skilled evaluation of the extra textual material placed
before it and exclude the essentially unreliable. "Nevertheless the court, as master of its own
procedure, retains a residuary right to admit them where, in rare cases, the need to carry out
the legislature's intention appears to the court so to require."

DICTIONARY
Words used in a statute should be interpreted in the light of their ordinary sense. To find out
the ordinary sense of the words, dictionaries can naturally be of help, Dictionaries can,
therefore, be consulted by the courts whenever the need arises to know the ordinary sense of
a word. But the courts must be careful because it is not necessary that dictionary meanings of
a word may be the true meaning in a particular context. "It is for the court to interpret the
statute as best as it may. In so doing the court may no doubt assist themselves in the
discharge of their duty by any literary help they can find, including of course the consultation
of standard authors and reference to well-known and authoritative dictionaries." la Lord
Coleridge observed "I am quite aware that dictionaries are not to be taken as authoritative
exponents of the meanings of words used in Act of Parliament, but it is well known rule of
courts of law that words should be taken to be used in their ordinary sense and we are,
therefore, sent for instruction to these books.2 In Lee v. Showmen's Guild of Great Britain3 it
was said by Somerweli J. that it is often fallacious in considering the meaning of a phrase
consisting of two words ['unfair competition'] to find a meaning which each has separately
and then infer that the two together cover the combination so arrived at. The two together
may, as here, have acquired a special meaning of their own'.

2
R v. Peters (1886) 16 QBD 636 at p. 611.
3
(1952) 23 QB 329 at p. 338.

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Diverse meanings of words are given in a dictionary. It is very difficult for court to choose
the correct meaning out of the same. Under these circumstances the context in which the
word has been used becomes very important. The court should, therefore, always keep in
mind the context in which a word has been used while choosing the correct meaning of that
word.4
The meaning of particular words in an Indian statute is to be found not so much in a strict
etymological propriety of language nor even in popular sense, as in the subject or occasion on
which they used. But it is well known that words are generally used in their ordinary sense
and therefore, though dictionaries are not to be taken as authoritative in regard to the
meanings of the words used in statutes, they may be consulted.
In Voltas Ltd. v. Rolta India Ltd.,5 the Supreme Court has held that:
“Dictionaries can hardly be taken as authoritative exponents of the meanings of the words
used in legislative enactments for the plainest words may be controlled by a reference to the
context.
Similarly, Lexicons would only define an expression in terms of a decision given by a Court
of Law, and unless this decision was given under the Act in which the expression is used "it
involves" in the words of Ram Lal,J. in Frim Karam Narain Daulat Ram v. Colkart Bros.,6" a
dangerous method of interpretation."

HISTORICAL BACKGROUND
In order to arrive at the intention of the legislature, the state of law and judicial decisions
antecedent to and at the time the statute was passed are material matters to be considered.
Evidence of matters relating to such surrounding circumstances and historical investigation of
which judicial note can be taken by court, including reports of select committees and
statements of objects and reasons, can be resorted to for ascertaining such antecedent law and
for determining the intention of the legislature.
But the bill and reports of select committee are not legitimate material for arriving at the
construction of a statute, that is, for finding the meaning of words.
Parliamentary debates on the floor legislature are also inadmissible, because, the court is
concerned only with what the legislature actually said in the statute.
Moreover, plain words in the statute cannot be limited by any considerations of policy.
4
See Commissioner of Wealth Tax Andhra Pradesh . Officer in Charge AIR 1977 SCM Singh State of Haryana
AIR 1989 SC 1367 Gramophone Company of Ind L B Rahadur Pandecy, AIR 1993 SC 2529 (229).
5
(2014) 4 SCC 516.
6
A.I.R. 1946 Lah (F.B) pp.116, 128.

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An erroneous assumption by the legislature as to the state of the law has no effect and would
not become a substantive enactment.
In the construction of a statute the worst person to construe it is the person who is responsible
for its drafting.
Courts sometimes make a distinction between legislative debates and reports of committees
and treat the latter as a more reliable or satisfactory source of assistance.
The speeches made by the members of the House in the course of the debate are not
admissible as extrinsic aids to the interpretation of statutory provisions.
It cannot be said that the acceptance or rejection of amendments to a Bill in the course of
Parliamentary proceedings forms part of the pre-enactment history of a statute and as such
might throw valuable light on the intention of the Legislature when the language used in the
statute admitted of more than one interpretation. The reason why a particular amendment was
proposed or accepted or rejected is often a matter of controversy and without the speeches
bearing upon the motion, it cannot be ascertained with any reasonable degree of certainty.
And where the Legislature happens to be bicameral, the second Chamber may or may not
have known of such reason when it dealt with the measure.
Courts while interpreting a statutory provision, can take into account relevant historical facts
or history of enactment in order to understand the subject matter of statute. Court can also
have regard to the surrounding circumstances which existed at the time of passing of the
statute. But, like any other external aid, the inference from historical facts and surrounding
circumstances must give way to the clear language employed in the enactment itself. In this
regard, Supreme Court in Mohanlal Tripathi v. Distt. Magistrate Rail Bareilly and others7has
observed:
“Value of ‘historical evolution’ of a provision or ‘reference’ to what preceded the enactment
is an external aid to understand and appreciate the meaning of a provision, its ambit or
expanse has been judicially recognized and textually recommended. But this aid to construe
any provision which is ‘extremely hazardous’ should be resorted to, only, if any doubt arises
about the scope of the section or it is found to be ‘sufficiently difficult and ambiguous to
justify the construction of its evaluation in the statute book as a proper and logical course
and secondly, the object of the instant enquiry’ should be ‘to ascertain the true meaning of
that part of the section which remains as it was and which there is no ground for thinking of
the substitution of a new proviso was intended to alter’.”

7
(1992) 4 SCC 80.

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This rule of admissibility permits recourse to historical works, pictures, engraving and
documents where it is important to ascertain ancient facts of a public nature. Recently,
Supreme Court while dealing with the Dental Act, 1948 in Dental Council of India v
Hariprakash8 has observed:
“The Act is a pre constitutional enactment but it has application in the post constitutional era
also. When interpreting such an enactment, we have not only to bear in mind the historical
background leading to the legislation and the amendments effected therein, but also various
aspects covered by it”.
It is apparent from this discussion that historical facts and surrounding circumstances are also
relevant facts to be taken into account by the Court as external aids for interpretation of
statutes.

TEXT BOOKS
Text books may be referred to by the courts to arrive at the true meaning of an enactment. It
is, however, not necessary that the views expressed therein are the views of the court also.
There have been instances of both acceptance and rejection by the courts of the opinions
expressed in text books. Manu, Yajnavalkya, Vijnaneshwara, Jimutavahana and Kautilya
have been frequently quoted by courts with approval. Mulla has also been referred time and
again.
In the English case of Bastin v. Davies,9 Lord Goddard C.J. says at one place, while
interpreting the word 'substance in the light of discussions in the twelfth edition of Sale of
Food and Drugs by Bell: "This court would never hesitate to disagree with a statement in a
text book, however authoritative, or however long it had stood, if it thought right to do so."
He goes on to say, "it would be unfortunate if doubt had to be thrown in a statement which
has appeared in a well-known text book for a greater number of years without being
judicially doubted and after it had been acted on by justices and their clerks for many years."
In Kesavananda Bharati v. State of Kerala,10 a large number of text books were quoted but
most of the Judges of the Supreme Court deciding this case were of the opinion that in view
of many opinions and counter-opinions it was not desirable to follow the opinions and that
the safest course for the court was to interpret keeping in mind always the whole context of
the issues.

8
(2001) 8 SCC 61.
9
(1950) 2 KB 579.
10
AIR 1973 SC 1461.

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Similarly, Supreme Court used information available on internet for the purpose of
interpretation of statutory provision in Ramlal v State of Rajasthan11. Courts also refer
passages and materials from text books and articles and papers published in the journals. We
are of the view that these external aids are very useful tools not only for the proper and
correct interpretation or construction of statutory provision, but also for understanding the
object of the statute, the mischief sought to be remedied by it, circumstances in which it was
enacted and many other relevant matters. In the absence of the admissibility of these external
aids, sometime court may not be in a position to do justice in a case.
STATEMENT OF OBJECTS AND REASONS
The Statement of Objects and Reasons, seeks only to explain what reasons induced the mover
to introduce the bill in the House and what objects he sought to achieve. But those objects
and reasons may or may not correspond to the objective which the majority of members had
in view when they passed it into law. The Bill may have undergone radical changes during its
passage through the House or Houses, and there is no guarantee that the reasons which led to
its introduction and the objects thereby sought to be achieved have remained the same
throughout till the Bill emerges from the House as an Act of the Legislature, for they do not
form part of the Bill and are not voted upon by the members. The Statements of Objects and
Reasons appended to the Bill should be ruled out as an aid to the construction of a statute.

PRECEDENTS
Under this rule, a principle of law which has become settled by a series of decisions is
generally binding on the courts and should be followed in similar cases. The rule is based on
expediency and public policy. It is however not universally applicable. For example, if
grievous wrong may result, a court will not follow the previous decisions which, they are
convinced, are erroneous.
While dealing with the provision of Sec. 207 of the Motor Vehicle Act, 1988, Hon’ble Mr.
Justice C.K. Thakkar in the case of Ramkrishna Bus Transport and Ors v. State of Gujarat
and Ors,12 held that, whether a particular provision is mandatory or directory depends upon
intention of the Legislature and not only upon the language in which it is used. The meaning
and intention of the Legislature must be treated as decisive and they are to be ascertained not
only form the phraseology used but also by considering the nature, design and consequences

11
(2001) 1 SCC 175.
12
1995 (1) G.L.H 520.

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which would flow from construing it one way or the other. It is also true that in certain
circumstances, the expression ‘may’ can be construed as ‘shall’ or vice versa. At the same
time, however, it cannot be ignored that ordinarily ‘may’ should read as ‘may’ which is
permissive and not obligatory. For the purpose of giving effect to the clear intention of the
legislature, ‘may’ can be read as ‘shall’ or ‘must’.
In Mahadeolal Kanodia v. Administrator General of W.B.13 the Supreme Court was
concerned with the retrospectivity of law passed by the West Bengal Legislature concerning
the rights of tenants and in para 8 of the judgment the Supreme Court held that:
The principles that have to be applied for interpretation of statutory provisions of this nature
are well established. The first of these is that statutory provisions creating substantive rights
or taking away substantive rights are ordinarily prospective; they are retrospective only if by
express words or by necessary implication...”
In Amireddi Raja Gopala Rao v. Amireddi Sitharamamma,14a Constitution bench was
concerned with the issue as to whether the rights of maintenance of illegitimate sons of a
Sudra as available under the Mitakshara School of Hindu law were affected by introduction
of Sections 4, 21 and 22 of the Hindu Adoptions and Maintenance Act, 1956. The Court held
that they were not, and observed in para 7 as follows:
... a statute should be interpreted, if possible, so as to respect vested rights, and if the words
are open to another construction, such a construction should never be adopted.”
The same has been the view taken by a Bench of three Judges of the Supreme Court in ITO v.
Induprasad Devshanker Bhatt,15 in the context of a provision of the Income Tax Act, 1961, in
the matter of reopening of assessment orders. In that matter the Court was concerned with the
issue as to whether the Income Tax Officer could reopen the assessment under Sections
297(2)(d)(ii) and 148 of the Income Tax Act, 1961, although the right to reopen was barred
by that time under the earlier Income Tax Act, 1922. The Supreme Court held that the same
was impermissible and observed in para 5 as follows:
... The reason is that such a construction of Section 297(2)(d)(ii) would be tantamount to
giving of retrospective operation to that section which is not warranted either by the express
language of the section or by necessary implication. The principle is based on the well-known
rule of interpretation that unless the terms of the statute expressly so provide or unless there is
necessary implication, retrospective operation should not be given to the statute so as to

13
AIR 1960 SC 936.
14
AIR 1965 SC 1970 : (1965) 3 SCR 122.
15
AIR 1969 SC 778.

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affect, alter or destroy any right already acquired or to revive any remedy already lost be
efflux of time.”
In Voltas Ltd. v. Rolta India Ltd.,16 the Supreme Court has held that:
“We are absolutely conscious that a judgment is not to be read as a statute but to understand
the correct ratio stated in the case it is necessary to appreciate the repetitive use of the
words.”
In the case of Narmada Bachao Andolan v. State of Madhya Pradesh & Anr.,17 the Supreme
Court has observed that:
“The Court should not place reliance upon a judgment without discussing how the factual
situation first in with a fact situation of the decision on which reliance is placed, as it has to
be ascertained by analyzing all the material facts and the issues involved in the case and
argued on both sides. A judgment may not be followed in a given case if it has some
distinguishing features. A little difference in facts or additional facts may make a lot of
difference to the presidential value of a decision. A judgment of Court is not to be read as a
statute, as it is to be remembered that judicial utterances have been made in setting of the
facts of a particular case. One additional or different fact may make a world of difference
between the conclusions in two cases. Disposal of case by blindly placing reliance upon a
decision is not proper.
“Per incuriam” are those decisions given in ignorance or forgetfulness of some statutory
provisions or authority binding on the Court concerned, or a statement of law caused by
inadvertence or conclusion that has been arrived at without application of mind or proceeded
without any reasons so that in such a case some part of the decision or some step in the
reasoning on which it is based, is found, on that account to be demonstrably wrong.
In the case of Sakshi v. Union of Inaia & Others,18 the Supreme Court has observed that:
“ Stare decisis is a well-known doctrine in legal jurisprudence. The doctrine of stare decisis,
meaning to stand by decided cases, rests upon the principle that law by which men are
governed should be fixed, definite and known, and that, when the law is declared by a court
of competent jurisdiction authorized to construe it, such declaration, in absence of palpable
mistake or error, is itself evidence of the law until changed by competent authority. It
requires that rules of law when clearly announced and established by a court of last resort
should not be lightly disregarded and set aside but should be adhered to and followed. What

16
Ibid.
17
AIR 2011 SC 1989
18
(2004) 5 SCC 518.

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is precludes is that where a principle of law has become established by a series of decisions, it
is binding on the courts and should be followed in similar cases. It is a wholesome doctrine
which gives certainty to law and guides the people to mould their affairs in future.
In Mishri Lal v. Dhirendra Nath19 importance of this doctrine was emphasized for the
purpose of avoiding uncertainty and confusion and paras 14, 15, 16 and 21 of the report read
as under: (SCC pp.18-19 & 20-21)
“This Court in Maktul v.Manbhari20 explained the scope of the doctrine of stare decisions
with reference to Halsbury’s Laws of England and Corpus Juris Secundum in the Following
manner: ‘the principle of stare decisis is thus stated in Halsbury’s Laws of England, 2nd
Edn.:
“Apart from any question as to the courts being of coordinate jurisdiction, a decision which
has been followed for a long period of time, and has been acted upon by persons in the
formation of contracts or in the disposition of their property, or in the general conduct of
affairs, or in legal procedure or in other ways, will generally be followed by courts of higher
authority than the court establishing the rule, even though the court before whom the matter
arises afterwards might not have given the same decision had the question come before it
originally. But the Supreme Appellate Court will not shrink from overruling a decision, or
series of decisions, which establish a doctrine plainly outside the stature and outside the
common law, when no title and no contract will be shaken, no persons can complain, and no
general course of dealing be altered by the remedy of a mistake.”
The same doctrine is thus explained in Corpus Juris Secundum-
“Under the stare decisis rule, a principle of law which has become settled by a series of
decisions generally is binding on the courts and should be followed in similar cases. This rule
is based on expediency and public policy, and, although generally it should be strictly
adhered to by the courts, it is not universally applicable.”
Be it noted however that the Corpus Juris Secundum adds a rider that ‘previous decisions
should not be followed to the extent that grievous wrong may result; and accordingly, the
courts ordinarily will not adhere to a rule or principle established by previous decisions which
they are convinced is erroneous. The rule of stare decisis is not so imperative or inflexible as
to preclude a departure therefrom in any case, but its application must be determined in each
case by the discretion of the court, and previous decisions should not be followed to be extent
error may be perpetuated and grievous wrong may result.’

19
(1999) 4 SCC 11.
20
AIR 1958 SC 918.

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The statement though deserves serious consideration in the event of a definite finding as to
the perpetration of a grave wrong but that by itself does not denude the time-tested doctrine
of stare decisis of its efficacy. Taking recourse to the doctrine would be an imperative
necessity to avoid uncertainty and confusion. The basis feature of law is its certainty and in
the event of there being uncertainty as regards the state of law – the society would be in utter
confusion the result effect of which would bring about a situation of chaos - a situation which
ought always to be avoided.
In this context reference may also be made to two English decisions:
(a) in Admiralty Commrs. V/s. Valvendra (Owners)21wherein the House of Lords observe d
that even longestablished conveyancing practice, although not as authoritative as a judicial
decisions, will cause the House of Lords to hesitate before declaring it wrong, and
(b) in Button V. Director of Public Prosecution22 the House of Lords observed:
‘In Corpus Juris Secundum, a contemporary statement of American law, the stare decisis rule
has been stated to be a principle of law which has become settled by a series of decisions
generally, is binding on the courts and should be followed in similar cases. It has been stated
that this rule is based on expediency and public policy and should be strictly adhered to by
the courts. Under this rule courts are bound to follow the common law as it has been
judicially declared in previously adjudicated cases and rules of substantive law should
be reasonably interpreted and administered. This rule has to preserve the harmony and
stability of the law and to make as steadfast as possible judicially declared principles
affecting the steadfast as possible judicially declared principles affecting the rights of
property, it being indispensable to the due administration of justice, especially by a court of
last resort, that a question once deliberately examined and decided should be a question once
deliberately examined and decided should be a question once deliberately examined and
decided should be considered as settled and closed to further argument. It is a salutary rule,
entitled to great weight and ordinarily should be strictly adhered to by the courts. The courts
are slow to interfere strictly adhered to by the courts. The courts are slow to interfere with the
principle announced by the decision, and it may be upheld even though they would decide
otherwise were the question a new one, or equitable considerations might suggest a different
result and although it has been erroneously applied in a particular case. The rule represents an
element of continuity in law and is rooted in the psychologic need to satisfy reasonable
expectations, but it is a principle of policy and not a mechanical formula of adherence to the

21
1938 AC 173 : (1938) 1 ALL ER 162 (HL).
22
1966 AC 591 : (1965) 3 ALL ER 587 (HL).

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latest decisions however recent and questionable when such adherence involves collision
with a prior doctrine more embracing in its scope, intrinsically sounder and verified by
experience.’ ”
Foreign Decisions
For the purpose of construction of Indian statutes, courts also refer to decisions of foreign
courts which are following same system of jurisprudence as ours. The assistance of such
decisions is subject to the qualification that prime importance is always to be given to the
language of the relevant Indian statute, the circumstances and the setting in which it is
enacted and the relevant conditions in India where it is to be applied. These foreign decisions
have persuasive value only and are not binding on Indian courts and where guidance is
available from binding Indian decisions, reference to foreign decisions is of no use in,
Forasol v ONGC23; General ElectricCo. v. Renusagar Power Co.24
While interpreting provisions relating to fundamental rights contained in the Indian
Constitution, Supreme Court took much assistance from American precedents. In case where
an International Convention is involved, it is obviously desirable that decisions in different
jurisdictions across the world should so far as possible be kept in line with each other.
Therefore, in such cases foreign decisions are more useful for guiding the courts.

23
AIR 1984 SC 241.
24
(1987) 4 SCC 137).

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 CONCLUSION
The chief source of law is legislation, though there are other sources of law such as
precedents and customs. Every source of law finds its expression in a language. Often the
language has a puzzling effect, i.e., it masks and distorts. Often it is found that the language
of a statute is not clear. The words used in the statute too at times seem to be ambiguous.
Sometimes it is not possible to assign the dictionary meaning to certain words used in
legislation. Meaning which is to be assigned to certain words in legislation. Even the
dictionary does not give the clear-cut meaning of a word. This is so because the dictionary
gives many alternative meanings applicable in different contexts and for different purposes so
that no clear field for the application of a word is easily identified. So long as expansion of
meaning takes place uniformly, the law will develop along healthy lines. But if one judge
takes the narrow view and the other the broad view, the law will mean different things for
different persons and soon there will be confusion. Hence, it is necessary that there should be
some rules of interpretation to ensure just and uniform decisions. Such rules are called rules
of interpretation. There are various aids to the rule of interpretation and in case the ambiguity
is not removed even after applying the internal aids, then the external aids can come in handy.
They provide various methods by the help of which a statute can be interpreted and used by
the judiciary in deciding cases.
The importance of use of these aids is manifest. In any case, where difficulty arises as to
finding out the true intention of the legislature, the use of these materials could be made by
the Courts. Of course, in India, there is no consistent and uniform approach to the use of
extrinsic materials in the sense of determining as an aid for the purpose of interpretation of a
given statute. Undoubtedly, individually as well as collectively, they are very much useful in
finding out the true intention of the legislature. Of course, recourse to this aid could only be
made in case of possibility of more than one interpretation of a given statute.

15
 BIBLIOGRAPHY
1. BINDRA N.S., 'INTERPRETATION OF STATUTES', 5TH EDN., LAW BOOK

COMPANY,

2. PAPERS.SSRN.COM, EXTERNAL AIDS TO INTERPRETATION OF

STATUTES: A CRITICAL APPRAISAL BY SWATI RAO.

3. VARGHESE & POTTY, 'INTERPRETATION OF STATUTES PRINCIPLES OF

LEGISLATION & LEGISLATIVE DRAFTING, 6TH REVISED EDN. LAW BOOK

CENTRE.

4. CENTRAL LAW AGENCY, THE INTERPRETATION OF STATUTE; 10TH

EDITION, 2017-18.

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