Interpretation of statutes refers to the process of understanding and giving meaning to the

provisions and provisions of a law or statute. When laws are enacted by legislatures, they are
often written in broad and general terms, which can lead to different interpretations and
understandings. The role of statutory interpretation is to clarify the meaning and intention
behind the statutory language.

Statutory interpretation is a critical aspect of the legal system, allowing courts to understand
and apply legislation effectively. The primary rules of interpretation are foundational
principles used by courts to determine the meaning of statutes. These rules help ensure that
laws are applied consistently and fairly.

Literal Rule
The literal rule is a basic principle of interpretation that requires statutes to be interpreted
according to their plain and grammatical meaning. This rule is based on the assumption that
the legislature intends for the ordinary meaning of the words used in the statute to apply.
However, the literal rule is not applied inflexibly, and courts may depart from the literal
meaning of a statute if it leads to absurd or unreasonable results.
The essence of the literal rule can be summarised as follows:
“The focus should be on what the law says rather than what the law means.”
Motipur zamindari Co. (Pvt) Ltd v. State of Bihar 1962: The question raised was whether
the Bihar Sales Tax Act which exempted vegetables should exempt sugarcane or not.
Supreme Court opined that if we look at the dictionary or botanical meaning then vegetables
include sugarcane, but is not something which is grown by people in there garden and
therefore is not a part of vegetables. So, So, sugarcane was liable liable to to be included in
the category of tax paying essentials.

The sugarcane was not a green vegetable and was not exempted under the said entry. The
word vegetable in the taxing statutes was to be understood as in common Parlance that is
denoting the class of vegetables which were grown in a kitchen garden or in a farm and were
used for the table.

In the case of Tata Consultancy Services v. State of A.P. (2005) 1 SCC 308, it was held
that:
“A literal construction should not be denied simply because complying with it may result in a
penalty. The courts should not be overly eager to find ambiguities or obscurities in plain
words.”
Golden Rule
The golden rule allows courts to depart from the literal meaning of a statute if following the
literal meaning would lead to absurdity. Under this rule, courts may interpret statutes in a
manner that avoids absurd or unreasonable results, even if it requires departing from the
literal meaning of the words used.

The golden rule serves as a compromise between the literal rule and the mischief rule. It
generally gives words their plain and ordinary meaning but allows for deviations when
adhering strictly to the literal meaning would lead to an irrational outcome contrary to
legislative intent.
In cases of homographs, where a word has multiple meanings, the judge can apply the most
appropriate meaning. Similarly, if a word has only one meaning but using it would result in
an unfavourable decision, the judge can assign a completely different meaning altogether.
The golden rule can be applied in both a narrow and wide sense. Narrow use occurs when the
rule is applied to ambiguous words. This is the most common application of the rule. Wide
use occurs when the rule is employed to avoid outcomes that are contrary to public policy.

Mischief Rule
The mischief rule looks at the purpose or intent behind the statute in order to interpret its
provisions. This rule allows courts to interpret statutes in a manner that promotes the
underlying purpose or policy behind the law, even if it requires departing from the literal
meaning of the words used.
Heydon’s Case (1584) 3 CO REP outlined four points to be considered when interpreting a
statute:

What was the common law before the enactment of the statute?
What was the “mischief and defect” that the common law did not address?
What remedy did the parliament intend to provide to rectify the problem?
What is the true reason behind the remedy?
The use of this rule allows judges more flexibility in determining the lawmakers’ intent,
rather than being strictly bound by the literal and golden rules of interpretation.
However, this rule has been criticised on the grounds that it introduces uncertainty into the
law and grants excessive power to unelected judges, which is seen as undemocratic.
Moreover, it is considered outdated as the common law is no longer the primary source of
law.

Purposive rule
The purposive rule of interpretation, also known as the purposive approach or purposivism, is
a principle used by courts to interpret statutes by focusing on the underlying purpose or
objective of the legislation. Unlike the literal rule, which emphasizes the plain meaning of the
words used in the statute, the purposive rule looks beyond the literal meaning to determine
the legislative intent behind the statute.
Example: In Jones v. Tower Boot Co. Ltd, the UK House of Lords applied the purposive
approach to interpret a statute that prohibited discrimination on the grounds of sex. The court
held that the statute should be interpreted in a purposive manner to achieve the legislative
objective of combating sex discrimination, even if it required departing from the literal
meaning of the words used in the statute.

Conclusion
The primary rules of interpretation are essential tools used by courts to understand and apply
statutes. While these rules provide guidance, their application can vary depending on the
specific facts and circumstances of each case. Understanding these rules is crucial for anyone
involved in the legal profession to ensure that statutes are interpreted correctly and justly.