MISCHIEF RULE OF LAW IN THE EYES OF

INDIAN JUDICIARY

[This Final draft is submitted in the partial fulfillment of the requirement for the
award of degree B.A. LL.B (Hons.) for the course of Interpretation of Statutes
and Principles of Legislation for Academic Session 2021-22]

Submitted by:
Ram Kumar, B.A., LL.B. (Hons.) (1961)

Submitted to:
Dr. Father Peter Ladis F.
Professor, Interpretation of
Statutes and Principles of Legislation

AUGUST 2021
 DECLARATION BY THE CANDIDATE

I, hereby, declare that the work reported in the B.A., LL.B. (Hons.) Project Report titled
“MISCHIEF RULE OF LAW IN THE EYES OF INDIAN JUDICIARY” submitted at
CHANAKYA NATIONAL LAW UNIVERSITY, PATNA is an authentic record of my
work carried out under the supervisions of Dr. Father Peter Ladis F.. I have not submitted this
work elsewhere for any other degree or diploma. I am fully responsible for the contents of my
Project Report.

(Signature of the Candidate)

Ram Kumar (1961)

4th Year, B.A., LL.B. (Hons.)

SEMESTER – Seventh

CNLU, Patna

Dated: 31.08.2021

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 ACKNOWLEDGEMENT

I would like to show my gratitude towards my guides Dr. Father Peter Ladis F., Faculty of,
Interpretation of Statutes and Principles of Legislation under whose guidance, I structured my
project.

I owe the present accomplishment of my project to our CNLU librarians, who helped me
immensely with materials throughout the project and without whom I couldn’t have
completed it in the present way.

I would also like to extend my gratitude to my friends and all those unseen hands that helped
me out at every stage of my project.

THANK YOU.

RAM KUMAR

SEMESTER – Seventh

CNLU, PATNA

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Table of Contents
DECLARATION BY THE CANDIDATE.............................................................................2
ACKNOWLEDGEMENT..........................................................................................................3
Table of Contents........................................................................................................................4
Table of Cases.............................................................................................................................5
1. INTRODUCTION...............................................................................................................7
1.1 AIMS AND OBJECTIVES...............................................................................................8
1.2 HYPOTHESIS...................................................................................................................8
1.3 RESEARCH QUESTIONS...............................................................................................8
1.4 RESEARCH METHODOLOGY......................................................................................8
A. SOURCES OF DATA COLLECTION......................................................................9
B. METHODS OF DATA COLLECTION.....................................................................9
C. LIMITATIONS...........................................................................................................9
2. COPYRIGHT LAW IN INDIA.........................................................................................10
3. FAIR USE DOCTRINE: AN EXCEPTION TO INFRINGEMENT................................12
4. POSITION WORLDWIDE...............................................................................................13
Position in US........................................................................................................................13
Position in UK.......................................................................................................................13
Position in Australia..............................................................................................................14
5. INDIAN PERSPECTIVE OF FAIR DEALING...............................................................16
6. RAISON D’ETRE.............................................................................................................18
7. JUDICIAL TREATMENT OF FAIR DEALING.............................................................20
8. CONCLUSION..................................................................................................................26
Bibliography.............................................................................................................................28

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 Table of Cases

S.n Case Name Citation Pg.

o. No.
1. Academy of General Edu, Manipal and 2009(2) SCALE 310 Para 20 15
Anr v. B Malini Mallya
2. Barbara Taylor Bradford v. Sahara Media 2004 (28) PTC 474 (Cal) 21
Entertainment Ltd Para 56
3. Blackwood and Sons Ltd and Others v. AIR 1959 Mad 410 Para 84 15
AN Parasuraman and Ors.
4. CCH Canadian Ltd v. law Society of (2004)1S.C.R.339.2004SCC 14
Upper Canada 13
5. Civic Chandran v. Ammini Amma 1996 PTR 142 15
6. Eastern Book Company v. DB Modak AIR 2008 SC 809 Para 38 13
7. E M Forster and Anr v. A N Parasuram AIR 1964 Mad 331 Para 14 17
8. Folsom v. Marsh 9 F Cas 342 21
9. McMillan v. Khan Bahadur Shamsul ulma (1895) ILR Bom 557 12
Zaka
10. SK Dutt v. Law Book Co and Ors AIR 1954 All 570 Para 45 15
11. Super cassette Industries v. Nirulas Corner 148(2008) DLT 487 Para 20 16
House (P) Ltd
12. The Chancellor Masters and Scholars of 2008 (38) PTC 385(Del) Para 14,
the University of Oxford v. Narendra 33 16
Publishing House and Ors
13. Wiley Eastern Ltd and Ors v. Indian 61 (1996) DLT 281 Para 19 14
Institute of Management

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 Submitted By:
Parunjeet Singh Chawla
77/09
UILS, Panjab University

Table of Contents

Literal Meaning Modified 4

Lord Wensleydale's Golden Rule 4

Literal Golden Mischief 5

Interpretative Process 6

Application of Golden Rule 8

Indian Cases (Supreme Court) 10

Difficulties in the Application of Golden Rule 13

Criticism of Golden Rule 14

Conclusion 15

Bibliography 16

Table of Cases

1. Annapurna Biscuit Manufacturing Co. v. Commissioner of Sales Tax, U P 10

2. Becke v Smith ,(1836) 2 M&W 19 4
Collector of Customs, Baroda v Digvijayasinhji Mills AIR 1961 SC 1549
3. 6
4. Day Simpson (1885) 34 LJMC 149 7
5. Free Lanka Insurance Co. Ltd. v. Ranasinghe (1964) AC 541 7

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6. Glaxo Laboratories (I) Ltd. v. Presiding Officer AIR 1989 SC 505 15
7. Grey v. Pearson [1857] 6 H.L.C. 61 4,6,15
8. Inland Revenue Commissioner v. J.B. Hodge & Co. (Glasgow) Ltd.,
9. (1961) 1 WLR 92 7

10. Jugal Kishore Saraf v. Raw Cotton Co. Ltd, AIR 1955 SC 376 6
11. Lee v. Knapp (1966) 3 AH ER 961. 8
12. Matteson v Hart ,(1854) 23 LJCP 108 5
13. Narendra Kiadivalapa v. Manikrao Patil
14. Nokes v. Doncaster Amalgamated Collieries Ltd 3 All ER 549 (HL). 7,9
15. Nyadar Singh v. Union of India, AIR 1988 SC 1979 7

16. R. v. Sweden Lord Parker (1964) 1 WLR 1454. 7

17. Ramji Missar v. State of Bihar , AIR 1963 SC 1088: 9
18. Shamarac v. Parulkarv. Distt. Magistrate, Thana 1952 SCR 863. 12
19. ShriRam v State of Maharashtra AIR 1961 SC 674 6
20. State of Kerala v West Coast Planters MR 1958 Ker 41, 4
21. State of Rajasthan v. Mrs. Leela Jain AIR 1965 SC 1296 15
22. T.S. Baliah v. T.S. Regachari, AIR 1969 SC 701 5
23. Tirath Singh v. Bachitter Singh 10
24. Vacher v London Society of Compositors, [ 1913] AC 107 6

25. Warburton v Loveland, (1857) 6 HL 61, p 106,26 LJ Ch 473 4

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 1. INTRODUCTION

Legislative intent is sought in the actual words used which are under stood in their natural and
ordinary meaning and this is known as the grammatical interpretation or the literal rule of
interpretation .But sometimes this rule leads to absurdity and the golden rule comes in to
remove it .This rule is a departure from the literal rule of interpretation and asserts that the
literal rule may be modified.

Parke B in Becke v Smith1 formulated the following well-known rule for the interpretation of
statutes:

If the precise words used are plain and unambiguous, in our judgment, we are bound to
construe them in their ordinary sense, even though it does lead, in our view of the case, to an
absurdity or manifest injustice. Words may be modified or varied where their import is
doubtful or obscure, but we assume the function of legislators when we depart from, the
ordinary meaning of the precise words used merely because we see, or fancy we see, an
absurdity or manifest injustice from an adherence to their literal meaning.

Burton J in Warburton v Loveland,2 observed:

I apprehend it is a rule in the construction of statutes, that, in the first instance, the
grammatical sense of the words is to be adhered to. If that is contrary to, or inconsistent with
any expressed intention, or declared purpose of the statute, or if it would involve any
absurdity, repugnance, or inconsistency, the grammatical sense must then be modified,
extended, or abridged so far as to avoid such inconvenience, but no further.

Lord Wensleydale's Golden Rule

1
(1836) 2 M&W 191, 195,6LJEx54, 150 ER724; Allen, Law in the Making, fourth edn, pp 402-03; Abbey v
Dale, Jervis (1851) 20 LJCP 233, p 235; followed in State of Kerala v West Coast Planters MR 1958 Ker 41, p
43; Sirsilk Ltd v Govt ofAndhra Pradesh AIR 1960 AP 373, p 375.
2 (1929) 1 H&B IR 623, p 648:

Grammer may, no doubt, sometimes render assistance to law by helping to the construction, and thereby to the meaning of a sentence; but grammar, with reference to a living, and therefore, a
variable language, is perhaps more difficult to deal with than law, and the rules of legal construction are more certain than the rules of grammatical construction.

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Lord Wensleydale called it the 'golden rule' and adopted it in Grey v Pearson3 and thereafter it
is usually known as Lord Wensleydale's Golden Rule. This is another version of the golden
rule. His Lordship expressed himself thus:

I have been long and deeply impressed with the wisdom of the rule, now I believe universally
adopted at least in the courts of law in Westminster Hall that in construing wills, and indeed
statutes and all written instruments, the grammatical and ordinary sense of the words is to be
adhered to, unless that would lead to some absurdity or some repugnance or inconsistency
with the rest of the instrument, in which case the grammatical and ordinary sense of the words
may be modified, so as to avoid that absurdity and inconsistency, but no further.

It is a very useful rule in the construction of a statute to adhere to the ordinary meaning of the
words used, and to the grammatical construction, unless that is at variance with the intention
of the legislature to be collected from the statute itself, or leads to any manifest absurdity or
repugnance, in which case the language may be varied or modified so as to avoid such
inconvenience, but no further.

Jervis CJ, also described it as the 'golden rule' in Matteson v Hart4 We must, therefore, in this
case have recourse to what is called the golden rule of construction, as applied to Acts of
parliament, viz to give to the words used by the Legislature their plain and natural meaning,
unless it is manifest, from the general scope and intention of the statute, injustice and
absurdity would result from so construing them.

Thus, if the meaning of the words is at variance with the intention of the legislature to be
collected from the statute itself and leads to some absurdity or repugnance, then the language
may be varied or modified so as to avoid such inconvenience, absurdity or repugnance and no
further. The modern positive approach is to have a purposeful construction, which is to
effectuate the object and purpose of the Act. In other words ambiguity, inconsistency,
incompleteness in literal interpretation leads modification of language so as to avoid such
inconvenience. When in construing a word literally, there exist variance with the intention of
the legislature to be gathered from the subject or context of the statute, the language may be
varied or modified in such a case, but no further. Ambiguity here means double meaning, a
3
(1857) 6 HL 61, p 106,26 LJ Ch 473,p 481 Abbot v Middleton (1858) 11 ER 28 ,7 HLC 114 ,115 ,per Lord
Wensleydale
4
(1854) 23 LJCP 108 ,p 144

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word's expression capable of more than one meaning. A word is inconsistent when it is
incompatible with other words or gives separate meaning when read with other parts of the
statute. The word 'absurdity' also means 'repugnance': Repugnancy appears when there is a
direct conflict or inconsistencies like one provision says, "do" and other says, "don't." A
situation may be reached where it is impossible to obey the one without disobeying the other. 5
In all such cases, the statute becomes equivocal i.e., double meaning or questionable,
suspicious or uncertain in nature. Whenever the meaning of the word, phrase, expression or
sentence is uncertain, it may be a case of departing from the plain grammatical meaning, and
there may be need for application of golden rule.6 It is however reiterated in every concerned
case7, that the province of the judge is very different one of construing the language in which
the legislature has finally expressed. If they undertake the other province, which belongs to
the legislature who, have to endeavor to interpret the desire of the country, the courts are in
danger of going astray in a labyrinth to the character of which they have no sufficient guide.
And in this order again, the only safe course is to read the language of the statute in what
seems to be its natural sense. When we say that the ordinary and grammatical sense of the
words must be adhered to in the first instance, it means that most words have primary
meaning in which they are generally used, and such a meaning should be applied first. Words
have a secondary meaning also, that is a particular meaning in which they are used in a
particular context.

1.1 AIMS AND OBJECTIVES

The researcher intends to find out the following during the course of research:
i) To study the concept of Copyright Act.
ii) To study the doctrine of fair criticism under copyright laws of UK, US and India.
iii) To study the role played by the courts in interpreting fair criticism.

5
T.S. Baliah v. T.S. Regachari, AIR 1969 SC 701: (1969) 3 SCR 65: (1969) 72 1TR 787 (SC)
6
For example, Robert Wingram Crawford v. Richard Spooner. MIA 179 (PC)
7
G.W Paton, Jurisprudence (1946), p294

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1.2 HYPOTHESIS

The researcher assumed that the fair dealing under the Copyright Act should be limited in
scope in underdeveloping countries for its advancement.

1.3 RESEARCH QUESTIONS

The researcher has formulated the following research questions, the answer for which has
been found during the course of research:

i) What are the provisions of fair criticism under Indian Copyright Act, 1957 ?
ii) What is the scope of Section 51 of the Indian Copyright Act, 1957 ?
iii) What role court should play while assessing fair criticism under Copyright Act ?

1.4 RESEARCH METHODOLOGY

The researcher will do doctrinal type of research in which he will go through secondary
sources. The researcher through this methodology will be able to get a clear picture of the
problem in question. The doctrinal method helps in doing a comparative study of the topic.
This helps in getting the bird’s eye view of the subject.

A. SOURCES OF DATA COLLECTION

SECONDARY SOURCES: E-journals, Websites.

B. METHODS OF DATA COLLECTION

The researcher will make use of doctrinal methods that includes e-library work.

C. LIMITATIONS
The researcher has undergone time limitation.

Literal Golden Mischief 8

There are three fundamental rules9 suggested in the English Cases:

Firstly, the literal rule that, if the meaning of section is plain, it is to be applied whatever the
8
Bindra, N.S., The Interpretation of Statutes And General Clauses Acts (Central and State) with Phrases and
Words, Law Publishers, Allahabad, 1961.pp 564-565
9
Ibid

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In Ramji Missar v. State of Bihar10 in construing section 6 of the Probation of
Offenders Act, 1958, the Supreme Court laid down that the crucial date on which the age of
the offender had to be determined is not the date of offence, but the date on which the
sentence is pronounced by the trial court An accused who on the date of offence was below 21
years of age but on the date on which the judgment pronounced, if he was above 21 years, he
is not entitled to the benefit of the statute. This conclusion reached having regard to the object
of the Act. The object of the Statute is to prevent the turning of the youthful offenders into
criminals by their association with the hardened criminals of mature age within the walls of
the prison. An accused below 21 years is entitled to the benefit of the Act by sending him
under the supervision of the probation officer instead of jail.

In Narendra Kiadivalapa v. Manikrao Patil, 11 section 23 of the Representation

of People Act, 1951, which permitted inclusion of the name in the electoral roll "till the last
date for nomination" for an election in the concerned constituency, has been construed.
Section 33(1) of the R.P. Act, 1951 specifies that the nomination papers shall be presented
between the hours of 11'O clock in the fore noon and 3'0 clock in the after noon. Reading
these provisions together in the light of the object behind them, the Supreme Court construed
the words "last date" in section 23 as "last hour of the last date" of nomination under section
33(1) of the Act.

In Annapurna Biscuit Manufacturing Co. v. Commissioner of Sales Tax, U P., 12 Sales

Tax was fixed at two per cent, of the turnover in the case of "cooked food" under section 3A
of the U.P. Sales Tax Act, 1948. The appellant firm engaged in the business of biscuit
manufacture and sale. Whether biscuits though intended for human consumption, can be
construed as "cooked food" and liable to be taxed as per the notification issued under the said
provision. Held that if an expression is capable of a wider meaning, the question whether the
wider or narrower meaning should be accepted depends on the context of the statute. Here
biscuit was not covered within the words 'cooked food'. However, where the precise words
used are plain and unambiguous the court is bound to construe them in their ordinary sense

10
AIR 1963 SC 1088: (1963) Supp 2 SCR 745
11
AIR 1977 SC 2171
12
AIR 1981 SC 1656

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and not to limit plain words in an Act of Parliament by consideration of policy which has to
decided not by court but by Parliament itself.
In Tirath Singh v. Bachitter Singh13 the appellant argued that it was obligatory under
Section 99 (1) (a) of the Representation of the Peoples Act, 1951 for the tribunal to record
names of all persons who had been guilty of corrupt practices including parties and non-
parties to the petition and that under the proviso, notice should be given to all persons named
under Section 99(1)(a)(ii) He being a party to the petition was, therefore, entitled to a fresh
notice. Supreme Court said that such an interpretation will lead to an absurdity and held that
the proviso along with clause (b) thereto and the setting of the section pointed out that notice
is contemplated only against non- parties to the petition.

Difficulties in the Application of Golden Rule

Lord Moulten in Vacher & Sons v. London Society of Compositor 14 had explained the
reasons for adopting caution before application of the golden rule of construction in these
words: "There is a danger that it may generate into a mere judicial criticism of the propriety of
the Acts of legislature. We have to interpret statutes according to the language used therein,
and though occasionally the respective consequences of two rival interpretations may guide us
in our choice in between them, it can only be where, taking the Act as a whole and viewing it
in connection with the existing state of law at the time of the passing of the Act, we can
satisfy ourselves that the words cannot have been used in the sense the argument points. "It
may sometimes happen that laws made for the benefit of public at large may come in conflict
of some individual interest or take away his legal right and cause injustice to him. That is to
say, like public policy, absurdity, uncertainty or repugnance, are very unruly horses.
In State Bank of India v. Shri N. Sundara Money 15, the Supreme Court said that "it is the
duty of all courts of justice, to take care for the general good of the community, that hard
cases do not make bad law. Referring earlier cases the court observed that absurdity should be
understood in the same sense as repugnance that is to say something which would be as
absurd with reference to the other words of the statute as to amount to repugnance

13
AIR 1955 SC 850
14
 [1912] UKHL 3; (1913) AC 107
15
[1976] 3 S.C.R. 160

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Grundi v. Great Boulder Proprietary Cold Mines Ltd., 16 Lord Greene M.R. said, "Although
absurdity or non-absurdity of one conclusion as capered with another may be and very often
is, of assistance to the court in choosing between two possible meanings of ambiguous words.
The Golden Rule of Construction is a doctrine, which must be applied with great care,
remembering that judges may be fallible in this question of absurdity and in any event it must
not be applied so as to result in twisting language into a meaning, which it cannot bear. It is a
doctrine which must not be used to re-write the language in a way different from that in which
it was originally framed."
Criticism of Golden Rule
The Golden Approach can be criticized:
The United Kingdom Law Commissions commented in their report that:
“There is a tendency in our systems, less evident in some recent decisions of the courts but
still perceptible, to over emphasise the literal meaning of a provision (i.e. the meaning in the
light of its immediate and obvious context) at the expense of the meaning to be derived from
other possible contexts; the latter include the ‘mischief’ or general legislative purpose, as well
as any international obligation of the United Kingdom, which underlie the provision”.17
They also stated that to place undue emphasis on the literal meaning of words is to “assume
an unattainable perfection in draftsmanship”18 This was written in 1969 and in the light of
more recent judicial developments,19 it seems that the courts have shifted somewhat from the
literal approach. Zander20 contends that:“The main principles of statutory interpretation-the
literal rule, the golden rule and the mischief rule-are all called rules, but this is plainly a
misnomer(A misnomer is a term that suggests an interpretation known to be untrue). They are
not rules in any ordinary sense of the word since they all point to different solutions to the
same problem. Nor is there any indication, either in the so-called rules or elsewhere, as to
which to apply in any given situation. Each of them may be applied but need not be” Zander,
in his more recent book,21 criticized the golden rule for being silent as to how the court should
proceed if it does find an unacceptable absurdity
1. It suffers from the same difficulties as the literal approach vis lack of wider contextual
understandings of "meanings."

16
1948 1 All ER 21
17
“The Interpretation of Statutes”, (Law Com No 21) (Scot Law Com No 11), Report No 21, paragraph 80
(1969).
18
Ibid ,at para 30
19
Pepper v Hart [1992] 3 WLR 1032.
20
. The Law Making Process (2nd edition, 1985), 129 (http://lawaids.blogspot.com/2010/05/chapter-10-criticism-
of-golden-rule.html)
21
The Law Making Process (4th edition, 1994), 130

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2. The idea of "absurdity" covers only a very few cases. Most cases involve situations where
difficult choices have to be made between several fairly plausible arguments, not situations
where the words lead to obvious absurdities.
3. The use of the "absurdity" safety valve can be very erratic as pointed out by Professor
Willis in his famous article, "Statute Interpretation in a Nutshell" (l938) l6 C.B. Rev.l. Willis
at l3-l4:
What is an 'absurdity'? When is the result of a particular interpretation so 'absurd' that a court
will feel justified in departing from a 'plain meaning'? There is the difficulty. 'Absurdity' is a
concept no less vague and indefinite than plain meaning': you cannot reconcile the cases
upon it. It is infinitely more susceptible to the influence of personal prejudice. The result is
that in ultimate analysis the 'golden rule' does allow a court to make quite openly exceptions
which are based not on the social policy behind the Act, not even on the total effect of the
words used by the legislature, but purely on the social and political views of the men who
happen to be sitting on the case ...
What use do the courts make of the 'golden rule' today? Again the answer is the same - they
use it as a device to achieve a desired result, in this case as a very last resort and only after all
less blatant methods have failed. In those rare cases where the words in question are (a)
narrow and precise, and (b) too 'plain' to be judicially held not plain, and yet to hold them
applicable would shock the court's sense of justice, the court will if it wishes to depart from
their plain meaning, declare that to apply them literally to the facts of this case would result in
an 'absurdity' of which the legislature could not be held guilty, and, invoking the 'golden rule,'
will work out an implied exception. It was defined in Grey v. Pearson “the ordinary sense of
the words is to be adhered to, unless it would lead to absurdity, when the ordinary sense may
be modified to avoid the absurdity"

Conclusion
The 'Golden rule' could, thus, be explained as follows:—
1. It is the duty of the Court to give effect to the meaning of an Act when the meaning can be
fairly gathered from the words used, that is to say, if one construction would lead to an
absurdity while another will give effect to what common sense would show, as obviously

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intended, the construction which would defeat the ends of the Act must be rejected even if the
same words used in the same section, and even the same sentence, have to be construed
differently. Indeed, the law goes so far as to require the courts sometimes even to modify the
grammatical and ordinary sense of the words, if by doing so absurdity and inconsistency can
be avoided.22
2. The Court should not be astute to defeat the provision of the Act whose meaning is, on the
face of it, reasonably plain. Of course, this does not mean that an Act or any part of it can be
recast. It must be possible to spell the meaning contended for, out of the words actually
used.23
3. Unless the words are without meaning or absurd, it would be safe to give words their
natural meaning because the framer is presumed to use the language which conveys the
intention24 and it would not be in accord with any sound principle of construction to refuse to
give effect to the provisions of a statute on the very elusive ground that to give them their
ordinary meaning leads to consequences which are not in accord with the notions of propriety
or justice entertained by the Court. 25

Bibliography

22
See the Speech of Lordship Wensleydab in Grey v. Pearson [1857] 6 H.L.C. 61
23
Shamarac v. Parulkarv. Distt. Magistrate, Thana 1952 SCR 863.
24
Glaxo Laboratories (I) Ltd. v. Presiding Officer AIR 1989 SC 505.
25
State of Rajasthan v. Mrs. Leela Jain AIR 1965 SC 1296.

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1. Kafaltiya A.B.,Interpretatation of Statutes, Universal Law Publishing, 2008

2. Bindra, N.S., The Interpretation of Statutes And General Clauses Acts (Central and
State) with Phrases and Words, Law Publishers, Allahabad, 1961.

3. Gandhi, B.M., Interpretation of Statutes, Eastern Book Co., Lucknow, 2006.

4. Singh,G.P., Principles of Statutory Interpretation, Wadwa and Co., Nagpur, 2006.

5. Yog, A.K., Interpretation of Statutes, Modern Law Publishers, New Delhi, 2009.

6. Maxwell, Interpretation of Statutes, P.St. Langan, Lexis Nexis, 10th Edition,New Delhi,
2004

7. Bakshi P.M. , Interpretation of Statutes, Orient Publications., New Delhi (2008)

8. Bhattacharyya. T, The Interpretation of Statutes, Central Law Agency, Allahabad

(2009)

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