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Case Laws on Interpretation of

Statutes
Case Laws on Interpretation of Statutes

Literal or Grammatical Interpretation 

Maqbool Hussain Vs State of Bombay Gold (Sea Custom Act, FERA)

Ramavatar Vs Asstt. Sales Tax Officer Betal Leaves

Municipal Board Vs State Transport Authority, Rajasthan Location of Bus stand

Mischief Rule 

Kanwar Singh vs Delhi Adminstration Cattles

Ranjit Vs State of Mahrashtra Sales of obscene books

Alamgir Vs State of Bihar Wife u/s 498

RPF Vs Shree Krishna Metal Manufacturing Co PF-4 units Total exceeds 50 employees

Golden Rule 

The Tirath Singh Vs Bachitter Singh Notice to be given to non -parties

State of Punjab Vs Qaiser Jehan Begum Application for compensation submitted under Land
Acquisition Act from date of order or date of receipt of order

Assessing Authority Vs Patiala Biscuits Manufacturers Possession of Sales tax Registration certificate
under Punjab General Sales Tax Act 1948

Extrinsic Aids-

Legislative History 

A.K Gopalan Vs State of Madras Speech made in the course of parliament debate inadmissible

K.P Varghese Vs ITO Speech made by mover of the bill admissible

Penal Statutes to be construed strictly 

Sarjoo Prasad Vs State of U.P-Prevention of Food Adulteration Act,1954

Adulterated food.Was an employee in the shop.Section 16 covers employer and employee.Section 19

says absence of a guilt knowledge is not a defence.Hence employee convicted.
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Ranjit Vs State of Mahrashtra Sales of obscene books-Lady Chatterlies Lovers

Inder Sain Vs State of Punjab Opium -Narcotics : possession without knowledge.Word Possession in
Section 9 is not clear.Possession may mean mere possession or it may be possession with knowledge.

Kedar Nath Vs State of West Bengal Punishment of imprisonment or fine or both- Later extended by
amendment to an amount equivalent to amount procured by the offender through his offence. Only Ist
punishment can be levied under Article 20(1)

Ratan Lal Vs State of Punjab Outrage the modestly of women.16 yrs boy outraged modesty of girl of 7
yrs.Later Probation of Offenders Act,1958 came into existence.SC held benefit of probation could be
given to him.

Harmonious Construction

M.S.M Sharma Vs Krishna Sinha Breach of Privilege of House of Parliament.Publication of parts of

speech expunged by the Speaker.Article 19 and Article 194

Waverly Jute Mills Vs Raymon & Co Entries in various lists in Seventh Schedule.If one general and one
specific,general must be construed as excluding the specific.

Banarasi Vs ITO Notice u/s 34(1) of Income Tax Act 1922 (Saving of the same u/s 4 of Amending Act
1959).Notice served after 8 yrs.Question was issued and served.

Shankari Prasad Vs Union of India Fundamental Rights.Article 13(2) and Article 368

Beneficial Construction

Manohar Lal vs State of Punjab Close of 1 day in a week.Even if business is conducted by owner and his
family members.

U. Unichoyi Vs State of Karela Minimum Wages.Whether violative of article 19(1)(g).Act did not specify
minumim wages.Capacity of employer.SC held no.

S.K Verma Vs Industrial Tribunal cum labour court Continuous Service.Beneficial legislation.240 days
during 12 months.Deemed to be in continuous service.

All India Reporter Karmchari Sangh Vs All India Reporters Limited Law Reports are newspapers.Entitled
for Palekar Award.

Shashi Gupta Vs LIC Circular.Interpretation beneficial to the policy holder would be adopted.

Baldev Sahai Bangia Vs R.C Bhasin Baldev was Tenant.Migrated to Canada.Mother and brother
continued to live in the house.Held mother and brother are family.

Strict Interpretation

Union of India Vs Commercial Tax Officer Sales to Ministry Of Industry and Supplies,Govt of India.Act
exempted sales to Indian Stores Deptt or Supply Deptt of Govt. of India.Held not same as secifically two
departmens named.

Sevanti Lal Vs CIT Bombay Shares gifted to wife and then sold.Argued capital Gains could not be
included in his income.Held once a form is amended,amended form takes the place of the old form.

Ramavatar Vs Asstt. Sales Tax Officer Betal Leaves.Held not vegetable

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Dunlop India Ltd Vs Union of India V.P latex whether Rubber or not.Held rubber.

Seksaria Cotton Mill Co Vs State of Bombay Delivery to agent.Essential commodities Act case.Delivery
of cotton bales to Del Credere agent.

Doctrine of Pith & Substance

Subrahamanyam Chettiar Vs Muthuswamy Goundan True Nature & Character while making legislation.

Prafulla Kumar Mukherjee Vs Bank of commerce Docttrine applicable to Canada & Australia:not India
where three lists instead of two had been provided.

State of Bombay Vs F.N Balsara Bombay Prohibition Act,1949.Liquor whether Union or State
subject.Held Valid Law

O.N Mahindroo Vs Bar Council Advocate Act,1961 was challenged.Held it falls in Entries 77 and 78 of
the Union List and not within Entry 26 of the Concurrent List.

Doctrine of Severability

A.K Gopalan Vs State of Madras Preventive Detention Act,1950.Section 14 could be severed from the
rest of the Act and hence Valid.

State of Bombay Vs F.N Balsara Bombay Prohibition Act.8 Sections declared unconstitutional and could
be severed from the Act.

Doctrine of Territorial Nexus

State of Bombay Vs R.M.D .Chamarbangwala. Newspaper printed and published at Bangalore had wide
circulation in Bombay.Prize competitions in Bombay .Held Bombay could impose tax.

Tata Iron & Steel Co Vs State of Bihar Production or manufacture of Goods

State of Bihar Vs Charusila Das In case of Trust,State has authority to Enact laws regarding Trust and
Trustees etc.

Doctrine of Eclipse

Keshavan Madhava Vs State of Bombay Whether Prosecution Commenced prior to Constitution could
continue.Held yes.

Saghir Ahmed Vs State of UP Invalid Law

Mahendra Lal Jaini Vs State of UP Doctrine of eclipse applies only to Pre-constitutional Laws.

Doctrine of Colourable Legislation

K.C Gajapati Narayan Dev Vs State of Orissa Orissa Agricultural Income Tax act 1950 and Orissa Estate
Abolition Act 1952.Held not colourable even if motive was to reduce compensation by artificially
reducing net income of intermediaries.

K.T Moopli Nair Vs State of Karela Tax on Income-Travancore Cochin Land Tax Act.Tax was in five
figures for Income in four figures.Held unconstitutional because in the guise of tax,property was being
confiscated.
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State of Bihar Vs Kameshwar Singh Bihar Land Reforms Act,1950.First entire rent will go to State and
then half of the same will go to landholder.Held Colourable legislation since amounted to taking instead
of giving.

Interpretation of Statutes-Pari Materia

Hari Vs Deputy Commissioner of Police Section 57 of Bombay Police Act not in pari materia with Article
19(5) of the Constitution.

Lilavati Bai Vs State of Bombay Section 5 of Bombay Land Requisition Act,1948 not in Pari Materia with
Section 4(1) of Indian Electricity Act,1910.

Sonia Bhatia Vs State of UP Expression adequate consideration used in Section 5(6),proviso (b) of the
UP Imposition of Ceiling on LH Act,1961 to have same meaning as in Income Tax Act,1961.

Sirsilk Ltd Vs Textile Committee IRDA,1951 and Taxtile Committee act,1963 are not in para materia.

Construction 'Ejusdem Generis'

Commissioner of Income Tax Kolkatta Vs Smifs Securities Ltd Dep on Intangible assets u/s 32 of IT Act

State of Bombay Vs Ali Gulshan Requisition of Land under Bombay Land Acquisition Act u/s 6(4)(a)

Lilavati Bai Vs State of Bombay Requisition of Land under Bombay Land Acquisition Act u/s 6(4)(a)

Construction Noscitur a Sociis

To know from the association

Mangoo Singh Vs Election Tribunal Demand of Municipality taxes on the date of filing nomination

Alamgir Vs State of Bihar Wife u/s 498.

State of Rajasthan Vs Sripal Jain Compulsory retirement.Since it was not as a penalty,need not be sent
by Chief Minister to Governor.

Ut Res Magis Valeat Quam Pereat

When two alternative constructions are possible,the court must give effect to the one ensuring smooth
working rather than posing a hindrance.

Avtar Singh Vs State of Punjab Electricity theft case u/s 39 & 50 of Electricity act .Argument-It is not a
theft as per IPC.Held theft as Section 39 creates a fiction.

Tinsukia electric supply company limited vs State of Asam Instruction of statues to be operative

Expressio unius est exclusio alterius

Express mention of one thing implies the exclusion of another.

Nandini Satpathi Vs P.L Dani Confession and Admission are different.Confession is inadmissible but
admission is relevant.

Benetton Coleman vs Union of India Fundamental rights under Article 15,16,19 are avlbl to citizens and
hence non-citizens and legal persons are expressly excluded.
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Contemporanea Expositio Est Fortissima in Lege

Words of a statute should normally be understood in the sense they bore when it was passed. 

Raja Ram Vs State of Bihar

Excise officer is a Police officer u/s 25 of Evidence act

Doypack Sytems Pvt Ltd Vs Union of India Swadeshi Cotton Mills Co.Ltd(Acquisition and Transfer of
Undertaking)Act,1980 is a modern Act