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 Social Laws Today  Blog  Law School Assignment  GOLDEN RULE OF INTERPRETATION AND

CASES


LAW SCHOOL ASSIGNMENT LEGAL JUNGLE

GOLDEN RULE OF INTERPRETATION AND

CASES

BY SOCIAL LAWS TODAY  OCTOBER 21, 2021  3 COMMENTS  26 MINUTES READ  1 YEAR AGO

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Golden Rule of interpretation: Written By: Tshewang Dema

Table of Contents
1. INTRODUCTION
2. MEANING OF GOLDEN RULE OF INTERPRETATION
3. ORIGIN OF GOLDEN RULE OF INTERPRETATION
4. APPROACH OF THE GOLDEN RULE
5. SIGNIFICANCE OF GOLDEN RULE[10]
6. APPLICATION OF GOLDEN RULE
7. INDIAN CASE LAW
8. DIFFICULTIES IN THE APPLICATION OF GOLDEN RULE[24]
9. ADVANTAGES OF GOLDEN RULE[28]
10. DISADVANTAGE OF GOLDEN RULE[29]
11. CRITICISM OF THE GOLDEN RULE
12. CONCLUSION
13. BIBLIOGRAPHY

INTRODUCTION

“The essence of law lies in the spirit, not its letter, for the letter is significant only as being


the external manifestation of the intention that underlies it” – Salmond

Statutory interpretation is the process of interpreting and applying legislation to decide
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cases. Interpretation is necessary when the case involves subtle or ambiguous aspects of
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a statute. Generally, the words of a statute have a plain and straightforward meaning. But
in some cases, there may be ambiguity or vagueness in the words of the statute that must
be resolved by the judge. The reason for ambiguity or vagueness of legislation is the
fundamental nature of language. It is not always possible to precisely transform the
intention of the legislature into written words.

A judge is then forced to resort to the documentation of legislative intent, which may also
be unhelpful, and then finally to his or her own judgment of what outcome is ultimately fair
and logical under the totality of the circumstances. To find the meanings of statutes,
judges use various tools and methods of statutory interpretation, including traditional
canons of statutory interpretation, legislative history, and purpose. In common law 
jurisdictions, the judiciary may apply rules of statutory interpretation to legislation enacted
by the legislature or to delegated legislation such as administrative agency regulations.[1]


Very often occasions will arise where the courts will be called upon to interpret the words,
phrases and expressions used in the statute. There are numerous rules of statutory
interpretation. Over time, various methods of statutory construction have fallen in and out
of favour. Some of the better-known rules of construction methods are The Golden rule,
The Literal rule, The Mischief rule and The Purposive approach.[2]

Whenever literal interpretation leads to an irrational result that is unlikely to be the

legislature’s intention, the court can depart from that meaning. It is such a rule which
disposes of ambiguity’, inconsistency, unclarity, hardship, inconvenience, injustice, etc.
arose from the language of Statute while interpreting it. Hence the golden rule is an
exception and has an important place in the Interpretation of Statutes to the literal rule
and will be used where the literal rule produces the result where Parliament’s intention
would be circumvented rather than applied. Golden rule is a principle of statutory
construction that the grammatical and ordinary sense of words may be modified so as to
avoid an absurdity or inconsistency, but no farther.

Interpretation is of two kinds – grammatical and logical. Grammatical interpretation is

arrived at by reference to the laws of speech to the words used in the statute; in other
words, it regards only the verbal expression of the legislature. Logical interpretation gives
effect to the intention of the legislature by taking into account other circumstances
permissible according to the rules settled in this behalf. ‘Proper construction’ is not

satisfied by taking the words as if they wereKnow
self-contained phrases. So considered, the
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words do not yield the meaning of a statute.[3]

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A statute is the will of the legislature and the fundamental rule of interpretation, to which
all others are subordinate, and that a statute is to be expounded, according to the intent of
them that made it. The object of interpretation is to find out the intention of the legislature.

The primary and foremost task of a court in interpreting a statute is to ascertain the
intention of the legislature, actual or imputed. The words of the statute are to be construed
so as to ascertain the mind of the legislature from the natural and grammatical meaning
of the words which it has used. ‘The essence of the Law’, according to Salmond:[4]

“Lies in its spirit, nor in its letter, for the letter is significant only as being the external

manifestation of the intention that underlies it. Nevertheless, in all ordinary cases, the
courts must be content to accept the litera legis as the exclusive and conclusive evidence
of the sententia legis. They must, in general, take it absolutely for granted that the 
legislature has said what it meant, and meant what it has said.”

MEANING OF GOLDEN RULE OF

INTERPRETATION

The rule was defined by Lord Wensleydale in the Grey v Pearson case (1857)[5] as: “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 the absurdity and inconsistency, but no farther.”

Therefore, it is the modification of the literal rule of interpretation. The literal rule
emphasises on the literal meaning of legal words or words used in the legal context which
may often lead to ambiguity and absurdity. The golden rule tries to avoid anomalous and
absurd consequences from arising from literal interpretation. In view of the same, the
grammatical meaning of such words is usually modified.

The court is usually interested in delivering justice and in order to foresee the
consequences of their decisions the golden rule is usually applied. This rule of
interpretation aims at giving effect to the spirit of the law as the mere mechanical and
grammatical meaning may not be sufficient.
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According toPublish
Maxwell, “The golden rule is that words of Institute must prima facie be
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given their ordinary meaning”.
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According to Gray, “the process by which a judge (or indeed any person, lawyer or layman,
who has occasion to search for the meaning of a statute) constructs from words of a
statute book, a meaning which he either believes to be that of the legislature, or which he
proposes to attribute to it, is called interpretation”.

The words of a statute must be prima facie according to Golden Rule to be given their
ordinary meaning because when meaning of the word is plain, it is not the duty of the
courts to busy themselves with supposed intention. But when grammatical interpretation
leads to absurdity it is permissible to depart from and to interpret the provision of statues
in such a manner so that absurdity is removed.[6] 

The court when faced with more than one possible interpretation of an enactment is
entitled to take into consideration the result of each interpretation in a bid to arrive at the

true intention of the legislature. The golden rule provides no clear means to test the
existence or extent of an absurdity. It seems to depend on the result of each individual
case. Whilst the golden rule has the advantage of avoiding absurdities, it therefore has the
disadvantage that no test exists to determine what is an absurdity.

In short, it is an interpretation which will give effect to the purpose of legislature, when the
words itself becomes ambiguous, by modification of the language used. On the face of it,
this rule solves all problems and is therefore known as “Golden Rule”. Further since the
literal meaning is modified to some extent, this approach is also called the modifying
method of interpretation. This rule, therefore, suggests that the consequences or effect of
an interpretation deserve a lot more importance because there are clues too the true
meaning of a legislation.

ORIGIN OF GOLDEN RULE OF

INTERPRETATION

In the year 1857, for the first time, Lord Wensleydale propounded the golden rule of
interpretation, in Grey Vs. Pearson.[7] Thereafter this rule has become famous by the
name of Wensleydale’s Golden rule.

The Golden Rule was used in the R v Allen case (1872).[8] In this the defendant was
charged with bigamy (S.57 of offences against the person act 1861) which, under statutes

states: ‘whosoever being married shall marry any other personOpinion
during the lifetime of the
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former husband or wife is guilty of an offence’.

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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.

APPROACH OF THE GOLDEN RULE

The golden rule can be applied in two ways:


Narrow Approach– This approach is applied when the word or phrases capable of more
than one literal meaning. This allows the judge to apply the meaning which avoids the
absurdity. 

Broad Approach– This approach is applied when there is only one literal meaning. But
applying that one literal meaning would cause an absurdity. Under this approach the court
will modify the meaning to avoid the absurdity. The modification shall be keeping in mind
the intention of the Parliament making the law in question.

The golden rule of statutory interpretation allows a shift from the ordinary sense of a
word(s) if the overall content of the document demands it. It states that if the literal rule
produces an absurdity, then the court should look for another meaning of the words to
avoid that absurd result. 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 the absurdity and inconsistency, but no
farther.[9]

SIGNIFICANCE OF GOLDEN RULE[10]

The significance of the golden rule in the interpretation is explained followed:

It becomes the duty of the Court to give effect to meaning of a law when it can lead
to absurdity or defeat the ends of the enactment. The law requires the court sometimes
to go to the extent of modification in the grammatical and ordinary sense of the words
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 The court shall not go in the path thatKnow
defeats the provision of a law Law
whose meaning
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is, prima facie, reasonably plain and lucid. However, this dose not mean that a law could
be recast. It must be possible to find the meaning contended for out the words that are
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being used.
Unless the words of the law are absurd, ambiguous or without a proper meaning, it is
preferable to construe them through their natural and ordinary meaning.

APPLICATION OF GOLDEN RULE

The golden rule can be put forward as a compromise between the literal rule and the
mischief rule. It follows the path of literal interpretation by giving the status its ordinary
meaning. At the same time, when the literal interpretation leads to an irrational result
unlikely to the ends of the act, the court can deviate from the literal sense. Also, while 
using, abides by the public policy.[11]

An illustration of the use of the rule in its wider as well as its narrower sense is given 
below:

If there is a sign that say, “Do not use the elevators in case of fire”, the literal interpretation
would mean never to use the elevator while there is a fire. However, this interpretation is
absurd and what the sign truly tries to convey is to prevent using the elevators when a fire
is nearby.

While using the wider approach, the golden rule avoids a result that would go against the
public policy. For example, A son murders his mother and commits suicide. According to
the law, the heirs of the mother’s property would be either the mother’s family or the son’s
descendants. Since there is a question of profiting from the crime, the court is likely to
favour the mother’s family in the interest of public policy.

The Golden Rule enables the court to look at the literal meaning of an Act. This rule allows
a Judge to depart from a statute’s normal meaning to avoid an absurd result. This rule of
statutory interpretation may be applied when an application of the Literal Rule would lead
to an absurdity. The Golden Rule gives the words of a statute their basic, ordinary
meaning. However, when this may lead to an illogical result that is unlikely to be the
legislature’s intention, the golden rule allows a Judge to depart from this meaning.[12]

If the choice is between two interpretations, said Viscount Simon, L.C. in Nokes v.
Doncaster Amalgamated Collieries Ltd.[13] “We should avoid a construction which would

reduce the legislation to futility or the narrower one which would fail to achieve the
manifest purpose of the legislation. We should rather accept the bolder construction
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based on the view that Parliament would legislate only for the purpose of bringing about
an effective result. Thus, if the language is capable of more than one interpretation, one
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ought to discard the literal or natural meaning if it leads to an unreasonable result, and
adopt that interpretation which leads to reasonably practical results.”

In this case[14] Section 154 of the Companies Act, 1929, was in question. This provision
provided machinery for the transfer of the undertaking (an old company) to a new
company. Under the section, “transfer” includes all property, rights, liabilities and duties of
the former company vest with the latter. An issue therefore was whether a contract of
service previously existing between an individual and transferor company automatically
becomes a contract between the individual and the latter company.

Hence, an action was taken against him; however, no notice was given to him about the
proposed amalgamation either by the transferor or the transferee company. It was
contended that the contract of service could fall under the term “property”. Rejecting the
contention, the House of Lords held that the benefits of a contract entered into between
the former company and the employee cannot be transferred (by X company to Y
company) without the consent of the employee.

It is said that the application of Golden Rule of Construction, and its limits, can be seen in
the area devoted to construction with reference to the consequences, and construction to
avoid inconvenience and injustice, and to prevent evasion He illustrated the application of
the rule in various cases relating to criminal, civil, labour, revenue taxation and
administration branches of law.

INDIAN CASE LAW

In India there are several good examples where the Supreme Court or High Courts have
applied the Golden Construction of Statutes. Certain confusion one may face when it
appears that even for literal rule, this rule is named. As golden rule initially starts with the
search of literal meaning of the provision, and if there is unequivocal meaning, plain and
natural and no repugnancy, uncertainty of absurdity appears, apply the meaning. But when
there is possibility of more than one meaning, we have to go further to avoid the
inconvenience by even modifying the language by addition, rejection or substitution of
words so as to make meaning accurate expounding of intention of the legislature.[15]


In Uttar Pradesh Bhoodan Yagna Samiti v. Brij Kishore,[16] theOpinion
Supreme Court held that the
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expression “landless person” used in section 14 of U.P. Bhoodan Yagna Act, 1953 which
made provision for grant of land to landless persons,was limited to “landless laborers”. A
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landless labour is he who is engaged in agriculture but having no agricultural land. The
Court further said that “any landless person” did not include a landless businessman
residing in a city. The object of the Act was to implement the Bhoodan movement, which
aimed at distribution of land to landless labourers who were verged in agriculture. A
businessman, though landless cannot claim the benefit of the Act.

In Lee v. Knapp,[17] section 77(1) of the Road Traffic Act, 1960 provided that “a driver
causing accident shall stop after the accident”, the interpretation of the word “stop” was in
question. In this case, the driver of the motor vehicle stopped for a moment after causing

an accident and then ran away. Applying the golden rule the court held that the driver had
not fulfilled the requirement of the section, as he had not stopped for a reasonable period
so as to enable interested persons to make necessary inquires from him about the

accident at the spot of accident.

In Ramji Missar v. State of Bihar[18] 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 state of Punjab v. Qaiser Jehan Begum,[19] the respondent made an application under
Section 18 of the Land Acquisition Act, 1894 for reference to the civil court within six
months from he her knowledge of the award regarding compensation whereas the section
says that such reference would be made within six months from the date of the award.
Holding that the application was within time, Supreme Court held that unless an award of
compensation comes to the knowledge, either actually or constructively, how can a
reference, if any, be made against the award. Therefore, justice and fair play required that
the counting of the limitation period must begin from the date of knowledge of the award.

In Narendra Kiadivalapa v. Manikrao Patil,[20] section 23 of the Representation 33 of
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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.
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Section 33(1) of the R.P. Act, 1951 specifies that the nomination papers shall be presented
between the hours of 11’0 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 Tirath Singh v. Bachitter Singh[21] 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.

In Annapurna Biscuit Manufacturing Co. v. Commissioner of Sales Tax,[22] U P., Sales 34

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 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.[23]

DIFFICULTIES IN THE APPLICATION OF

GOLDEN RULE[24]

Lord Moulten in Vacher & Sons v. London Society of Compositor,[25] 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 usPublish
in our choice in between them, it can only be where, taking the Act as a
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whole and viewing it in connection with the existing state of law at the time of the passing
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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. Like public policy, absurdity, uncertainty or repugnance, are very
unruly horses.

In State Bank of India v. Shri N. Sundara Money,[26] 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

In the case of Grundi v. Great Boulder Proprietary Cold Mines Ltd.,[27] Lord Greene M.R.
said, “Although 38 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.”

ADVANTAGES OF GOLDEN RULE[28]

It allows the judge to choose the most sensible meaning where there is more than
one meaning to the words in the Act or Statute.
It respects the words of the parliament except in limited situations, the golden rule
provides an escape route where there is a problem with using the literal meaning.
It can also provide reasonable decisions in cases where the literal rule would lead to
repugnant situations (this goes for the wider meaning) – This is present in the Re
Sigsworth case in the case example, because allowing the son to benefit from his crime
would have been unjust.
A major advantage of the Golden Rule is that judge can technically change the law
by changing the meaning of words in statues. They can, potentially infringing the
separation of power between legal and legislature. 
 AnotherPublish
main advantages of the Golden Rule is that drafting errors inLaw
status can be
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corrected immediately. This is seen in the R V Allen (1872) case where the loopholes

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were closed, the decision was in line with parliament’s intentions, and it gave a more
just outcome.

DISADVANTAGE OF GOLDEN RULE[29]

There is no real guidelines as to when it can be used

It is very limited in it is use, so it is only used on rare occasions
It’s not always possible to predict whether courts will use the golden rule, making it
hard for lawyers and people who are advising their clients.
What seems to be absurd to one judge may not be to another so this means a case
outcome is decided upon the judge, rather than the law 
The Golden Rule won’t be help if there is no absurdity in the statute. For example, in
the case of London and North Eastern Railway v. Berriman,[30] where the widow

couldn’t get compensation because the wording of the statute didn’t allow for this
circumstance.

CRITICISM OF THE GOLDEN RULE

The Golden Rule is probably the most well-known ethical code of all time. It was used by
the Romans, the Chinese, the Greeks and adopted by every major religion imaginable. And
at first glance it does seem like a good ethical code to hold by as a society. However, the
golden rule is not only flawed and selfish, but it can also justify immoral acts. The main
reason for the golden rule is flawed is because the moral standard and criteria is not
based on others desires and preferences and it’s not even solely focused on what our
preferences and desires are. The Golden Rule implies the basic assumption that other
people would like to be treated the way that you would like to be treated. And with that we
are inevitably led to moral relativism, whatever your moral standard and desires are, is
what is morally good for others.[31]

Now such moral thinking can be counter-productive and used to justify immoral acts.
Consider a suicide bomber, a suicide bomber has no regard for his own life, he is literally
killing himself. According to the golden rule treating someone should be based on how you
want to be treated and since the suicide bomber is treating himself with death is it therefor
justified that he could kill others?


TheHome
word “absurdity” is a vague concept and arises only in a few cases where it necessary
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for the court to apply the golden rule of interpretation. Golden rule suffers from the same

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problems which were faced by the Literal approach i.e. lack of wider contextual
understanding of “meanings.” The majority of the cases contain tough scenarios where
touch choices have to be made between many credible arguments, not scenarios in places
where wordings of the legislation take you to obvious ambiguity.[32]

The ‘golden rule’ gives a court opportunities to create exceptions given public that are not
based on the social subject matter under the legislation, not even on the consequences of
the wordings made use by the law-making body, but entirely on the social and political
perceptions of the judges who deal with such difficult cases.

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. Following are criticized that is made by Zander about the golden rule for 

being silent as to how the court should proceed if it does find an unacceptable
absurdity[33]:

1. It suffers from the same difficulties as the literal approach vis a lack of wider
contextual understandings of “meanings.”
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”

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.

CONCLUSION

Every nation has its own judicial system, the purpose of which to grant justice to all. The
court aims to interpret the law in such a manner that every citizen is ensured justice to all.
To ensure justice to all the concept of canons of interpretation was expounded. These are
the rules which are evolved for determining the real intention of the legislature. 
It isHome
not necessary that the words used in aKnow
statute are alwaysOpinion
clear, explicit and
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unambiguous and thus, in such cases it is very essential for courts to determine a clear
and explicit meaning of the words or phrases used by the legislature and at the same time
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remove all the doubts if any.

Hence, the Golden Rule of Interpretation could be concluded as—[34]

If the language of Statute is clear, unambiguous, and ordinary, then its meaning
should be in accordance with that.
Statutes should be interpreted to materialize the intention of the legislature,
Words leading to more than one meaning should always be understood in the
meaning which is balanced and discretional.
Should avoid or prevent inconsistent or inconvenient results. 
Such interpretation should be avoided and the result is directly causing injustice.
Meaningless and Illogical Interpretation should not be accepted
If the language of Statute is not clear or leads to more than one meaning or not 
showing the intention of the legislature, then the language used in Statute could be
reformed and other rules of interpretation can be used for the help. This is the Golden
Rule of Interpretation.

BIBLIOGRAPHY

Books
Bhattacharyya Prof. T. Interpretation of Statutes, Central Law Agency. 2014

Langan P St. J, Maxwell on the interpretation of statutes, Lexi Nexis Butterworths

Wadhwa, Twelfth edition (2010).
Website
www.lawnotes.in
www.lawyersclubindia.com
www.inbrief.co.uk
https://www.iilsindia.com/blogs/golden-rule-of-interpretation/
https://blog.ipleaders.in/rules-interpretation-statutes/#The_Golden_Rule

https://www.pearsonhighered.com/assets/samplechapter/e/l/s/c/ELS_C%20and%20M
_Chap%203.pdf
https://www.lawteacher.net/free-law-essays/administrative-law/critical-analysis-of-

the-literal-golden-and-mischief-rule-law-essay.php
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[1] Indian Institute of legal studies, “Golden Rule of Interpretation”, available at:
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https://www.iilsindia.com/blogs/golden-rule-of-interpretation/ (visited on September 22,

2021).

[2] Prof. T. Bhattacharyya, The interpretation of Statutes (Central Law Agency, Allahabad,
10th edn, 2017).

[3] Prof. T. Bhattacharyya, The interpretation of Statutes (Central Law Agency, Allahabad,
10th edn, 2017).

[4] Internet Encyclopedia of Philosophy, “The Golden Rule”, available at:


https://iep.utm.edu/goldrule/ (visited on September 23, 2021).

[5] 1857) 6 HL 61, p 106,26 LJ Ch 473,p 481



[6] Brief regarding rules of interpretation of statutes, available at:

https://taxguru.in/corporate-law/rules-interpretation-statutes.html (visited on September
23, 2021).

[7] Ibid

[8] 2 ALL ER 641

[9] Becke v Smith,1836 150 E.R. 724 .

[10] Prof. T. Bhattacharyya, The interpretation of Statutes (Central Law Agency, Allahabad,
10th edn, 2017).

[11] Radhika Saxena “ The Golden Rule of Interpretation” 22 IJN 17 (2020).

[12] Sidharth Sabu “Golden Rule of Interpretation” 20 LLNN 12 (2020).

[13] 1940) AC 1014.

[14] Viscount Simon, L.C. in Nokes v. Doncaster Amalgamated Collieries Ltd. 1940) AC
1014.

[15] Shraddha Agrawal “The Golden rule of Interpretation”, available at:


https://www.lawctopus.com/academike/golden-rule-interpretation/#_edn52 (visited on
September 23, 2021).
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Social Laws Today
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[16] 1988 RD 363 (SC) Study Material 

[17] (1967) 2 QB 442.

[18] AIR 2003 P.& H. 135.

[19] AIR 1963 SC 1604

[20] AIR 1977 SC 2171

[21] AIR 1955 SC 850


[22] AIR 1981 SC 1656

[23] Prof. T. Bhattacharyya, The interpretation of Statutes (Central Law Agency, Allahabad,

10th edn, 2017).

[24] Shraddha Agrawal “The Golden rule of Interpretation”, available at:

https://www.lawctopus.com/academike/golden-rule-interpretation/#_edn52 (visited on
September 24, 2021).

[25] [1912] UKHL 3; (1913) AC 107

[26] [1976] 3 S.C.R. 160

[27] 1948 a ALL ER 21

[28] Golden Rule of Interpretation And Evolutionary Principals, available at:

https://www.academia.edu/34857472/GOLDEN_RULE_OF_INTERPRETATION_AND_EVOLU
TIONARY_PRINCIPALS (visited on September 23, 2021).

[29] Ibid

[30] [1946] AC 278

[31] Langan P St. J, Maxwell, The Interpretation of Statutes, Lexi Nexis Butterworths
Wadhwa, 12th edn., (2010).

[32] Rosedar S R A, Interpretation of Statutes, (Thomson Reuters, Haryana, 3rd edn., 2020).

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[34] Prof. T. Bhattacharyya, The interpretation of Statutes

Study Material  (Central Law Agency, Allahabad,
10th edn, 2017).

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