1.

DEFINITION OF INTERPRETATION
Interpretation is the process of explaining, expounding and translating any text or anything in
written form. This basically involves an act of discovering the true meaning of the language
which has been used in the statute. Various sources used are only limited to explore the written
text and clarify what exactly has been indicated by the words used in the written text or the
statutes.
Interpretation of statutes is the correct understanding of the law. This process is commonly
adopted by the courts for determining the exact intention of the legislature. Because the
objective of the court is not only merely to read the law but is also to apply it in a meaningful
manner to suit from case to case. It is also used for ascertaining the actual connotation of any
Act or document with the actual intention of the legislature.
2. MEANING OF INTERPRETATION OF STATUTES
What is the Interpretation of Statutes?
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.
Rules of interpreting statutes are necessary because laws must be applied to specific cases and
situations. It involves analysing the text of the statute, considering its purpose, examining the
legislative history and applying established legal principles and rules of interpretation. The goal
is to determine the legislative intent or the purpose the lawmakers sought to achieve when
enacting the law.
Courts, judges and legal professionals are primarily responsible for interpreting statutes when
resolving disputes or applying the law in specific cases. Different rules of interpretation of
Statutes may be employed, including textualism, which focuses on the plain meaning of the
words in the statute, which emphasises the legislative purpose and intent behind the law.
3. KINDS OF STATUTES
 Codifying statutes- The purpose of this kind of statute is to give an authoritative
statement of the rules of the law on a particular subject, which is customary laws. For
example- The Hindu Marriage Act, 1955 and The Hindu Succession Act, 1956.
 Consolidating statutes- This kind of statute covers and combines all law on a particular
subject at one place which was scattered and lying at different places. Here, the entire
law is constituted in one place. For example- Indian Penal Code or Code of Criminal
Procedure.
 Declaratory statutes- This kind of statute does an act of removing doubts, clarifying and
improving the law based on the interpretation given by the court, which might not be
suitable from the point of view of the parliament. For example- the definition of house
property has been amended under the Income Tax (Amendment) Act, 1985 through the
judgement of the supreme court.
  Remedial statutes- Granting of new remedies for enforcing one’s rights can be done
through the remedial statutes. The purpose of these kinds of statutes is to promote the
general welfare for bringing social reforms through the system. These statutes have
liberal interpretation and thus, are not interpreted through strict means. For example-
The Maternity Benefits Act, 1961, The Workmen’s Compensation Act, 1923 etc.
 Enabling statutes- The purpose of this statute is to enlarge a particular common law.
For example- Land Acquisition Act enables the government to acquire the public
property for the purpose of the public, which is otherwise not permissible.
 Disabling statutes- It is the opposite of what is provided under the enabling statute. Here
the rights conferred by common law are being cut down and are being restrained.
 Penal statutes- The offences for various types of offences are provided through these
statutes, and these provisions have to be imposed strictly. For example- Indian Penal
Code, 1860.
 Taxing statutes- Tax is a form of revenue which is to be paid to the government. It can
either be on income that an individual earns or on any other transaction. A taxing statute
thus, levies taxes on all such transactions. There can be income tax, wealth tax, sales
tax, gift tax, etc. Therefore, a tax can be levied only when it has been specifically
expressed and provided by any statute.
 Explanatory statutes- The term explanatory itself indicates that this type of statute
explains the law and rectifies any omission left earlier in the enactment of the statutes.
Further, ambiguities in the text are also clarified and checked upon the previous statutes.
 Amending statutes- The statutes which operate to make changes in the provisions of
the enactment to change the original law for making an improvement therein and for
carrying out the provisions effectively for which the original law was passed are
referred to as amending statutes. For example- Code of Criminal Procedure 1973
amended the code of 1898.
 Repealing statutes- A repealing statute is one which terminates an earlier statute and
may be done in the express or explicit language of the statute. For example-
Competition Act, 2002 repealed the MRTP Act.
 Curative or repealing statutes- Through these statutes, certain acts which would
otherwise be illegal are validated by curing the illegality and enables a particular line
of action.
4. PRIMARY RULES OF INTERPRETATION
THE PRIMARY RULE: LITERAL CONSTRUCTION
The rule of literal construction is considered to be the primary rule of interpretation. It is one
of the rules in which grammatical meaning of the word or phrase is used and this rule is also
called the grammatical rule of interpretation. Under this rule the court try to interpret Statute
on the literal, ordinary, popular, and common meaning of the word and phrases. This rule
postulates that it is duty of the court to expound the law as it stands and not to modify, alter or
quantify its language.
Plain and natural meaning: - In the literal interpretation of statute plain and natural meaning of
word or phrases to be referred in the case of legal word or phrase their legal meaning to be
referred. Sometimes the popular meaning of the word may not be the natural meaning of the
word or phrase, but the natural meaning must be referred to.
In the case of Municipal Board v. State Transport Authority, Rajasthan the location of bus stand
by changed by the local transport authority. Application against the order must be moved within
30 days from the date of the order. The issue raised be applicant is that the order can be moved
30 days from the knowledge of the order passed by Regional Transport authority. The Hon'ble
Supreme Court held that the since the language of the statute is plain and unambiguous
equitable consideration are out of place and clear grammatical meaning of the statute stand out.
5. LITERAL RULE OF INTERPRETATION, GOLDEN RULE OF
INTERPRETATION, MISCHIEF RULE OF INTERPRETATION, HARMONIOUS
CONSTRUCTION.
Literal or Grammatical Rule
It is the first rule of interpretation. According to this rule, the words used in this text are to be
given or interpreted in their natural or ordinary meaning. After the interpretation, if the meaning
is completely clear and unambiguous then the effect shall be given to a provision of a statute
regardless of what may be the consequences.
The basic rule is that whatever the intention legislature had while making any provision it has
been expressed through words and thus, are to be interpreted according to the rules of grammar.
It is the safest rule of interpretation of statutes because the intention of the legislature is deduced
from the words and the language used.
According to this rule, the only duty of the court is to give effect if the language of the statute
is plain and has no business to look into the consequences which might arise. The only
obligation of the court is to expound the law as it is and if any harsh consequences arise then
the remedy for it shall be sought and looked out by the legislature.
The Mischief Rule
Mischief Rule was originated in Heydon’s case in 1584. It is the rule of purposive construction
because the purpose of this statute is most important while applying this rule. It is known as
Heydon’s rule because it was given by Lord Poke in Heydon’s case in 1584. It is called as
mischief rule because the focus is on curing the mischief.
In the Heydon’s case, it was held that there are four things which have to be followed for true
and sure interpretation of all the statutes in general, which are as follows-
 What was the common law before the making of an act?
 What was the mischief for which the present statute was enacted?
 What remedy did the Parliament sought or had resolved and appointed to cure the
disease of the commonwealth?
 The true reason of the remedy.
 The purpose of this rule is to suppress the mischief and advance the remedy.
The Golden Rule
It is known as the golden rule because it solves all the problems of interpretation. The rule says
that to start with we shall go by the literal rule, however, if the interpretation given through the
literal rule leads to some or any kind of ambiguity, injustice, inconvenience, hardship, inequity,
then in all such events the literal meaning shall be discarded and interpretation shall be done in
such a manner that the purpose of the legislation is fulfilled.
The literal rule follows the concept of interpreting the natural meaning of the words used in the
statute. But if interpreting natural meaning leads to any sought of repugnance, absurdity or
hardship, then the court must modify the meaning to the extent of injustice or absurdity caused
and no further to prevent the consequence.
This rule suggests that the consequences and effects of interpretation deserve a lot more
important because they are the clues of the true meaning of the words used by the legislature
and its intention. At times, while applying this rule, the interpretation done may entirely be
opposite of the literal rule, but it shall be justified because of the golden rule. The presumption
here is that the legislature does not intend certain objects. Thus, any such interpretation which
leads to unintended objects shall be rejected.
Harmonious Construction
According to this rule of interpretation, when two or more provisions of the same statute are
repugnant to each other, then in such a situation the court, if possible, will try to construe the
provisions in such a manner as to give effect to both the provisions by maintaining harmony
between the two. The question that the two provisions of the same statute are overlapping or
mutually exclusive may be difficult to determine.
The legislature clarifies its intention through the words used in the provision of the statute. So,
here the basic principle of harmonious construction is that the legislature could not have tried
to contradict itself. In the cases of interpretation of the Constitution, the rule of harmonious
construction is applied many times.
It can be assumed that if the legislature has intended to give something by one, it would not
intend to take it away with the other hand as both the provisions have been framed by the
legislature and absorbed the equal force of law. One provision of the same act cannot make the
other provision useless. Thus, in no circumstances, the legislature can be expected to contradict
itself.
6. INTERNAL AIDS AND EXTERNAL AIDS OF INTERPRETATION.
Internal aids mean those materials which are available in the statute itself, though they may not
be part of enactment. These internal aids include, long title, preamble, headings, marginal
notes, illustrations, punctuation, proviso, schedule, transitory provisions, etc. Following are
internal aids in the interpretation of statutes:
(1) Short title: The short title is a nickname of statute, such as Indian Evidence Act, 1872,
Indian Penal Code, 1860. It identifies an Act but does not describe it. It only provides facility
of reference. The short title is merely for convenience.
(2) Long title: The long title of the Act may be referred for ascertaining its general scope and
throwing light on its construction. It is a legitimate aid. The long title of the Act is a part of it
and is admissible to construction.
(3) Preamble: The main objective and purpose of the Act are found in the Preamble of the
statute. It contains the recitals showing the reason for enactment of the Act. If the language of
the Act is clear the preamble must be ignored.
Example: The preamble of Indian Penal Code, 1860 reads: Whereas it is expedient to provide
a general Penal Code for India.
(4) Marginal Notes: Marginal notes are those notes which are inserted at the side of the
sections in an Act and express the effect of the sections.
Example: Section 11 of the Indian Contract Act, 1872 reads as: Who are competent to
contract?
Marginal notes appended to the articles of the Constitution have been held to constitute part of
the constitution as passed by the Constituent Assembly. Therefore, they have been used for
construing articles.
(5) Heading & title of a chapter: Headings may be given to group of sections in an Act. These
are generally treated as preamble to the group of sections. Headings prefixed to sections cannot
control the plain words of the provisions. Only in the case of ambiguity or doubt, heading or
sub-heading may be referred to as an aid in construing provision.
Example: The heading before Sections 172 to 190 of the Indian Penal Code, 1860 reads: “Of
the contempts of lawful authority of public servants”
Chapter titles or headings may be referred to as construction of doubtful expressions, but cannot
be used to restrict the plain terms of an enactment.
(6) Definitions/Interpretation clauses: Statutes contain definitions of certain words and
expressions used in an Act. Definition gives the interpretation of certain words or expressions,
they may include or exclude something, may be of restrictive extensive, ordinary or special
kind. When a word or expression has been defined prima facie, such definition governs that
word in the body of an Act everywhere, unless specially excluded. The object of definitions is
to avoid of frequent repetitions in describing the subject matter, to which the word or expression
so defined is intended to apply. A definition is not to be read in isolation, it must be read in
context of its use. Where definition itself is ambiguous, it has to be interpreted in the light of
other provisions of the Act.
(7) Proviso: A clause which is an exception to the main provision is known as proviso. Thus,
proviso is made when a special case is removed from the general clause and a separate
provision is made for it.
The normal function of a proviso is to except something out of the enactment or to qualify
something stated in the enactment which would be within its purview if the proviso were not
there.
(8) Illustrations or explanations: An illustration is appended to a section with the purpose of
illustrating the provision of law explained therein.
Example: 16 illustrations [(a) to (p)] have been appended to Section 378 of Indian Penal Code,
1860 which illustrate various aspects of the offence of theft.
Illustrations appended to sections are part of the statute and they help to furnish some indication
of the presumable intention of the legislature.
(9) Exceptions & saving clauses: The purpose of adding an exception to an enactment is
exempting something which would otherwise fall within the ambit of main provision.
Example: Five exceptions have been provided under Section 300 of the Indian Penal Code,
1860 which deals with those exceptional circumstances when culpable homicide is not murder.
Similarly, a saving clause is generally appended in cases of repeal and re-enactment of statute.
It is normally appended in the repealing statute and its object is that the right already created
under the repealed enactment is not disturbed.
(10) Schedules: The schedules are attached to statute to deal with as to how claims or rights
under it are to be asserted or as to how powers conferred under it are to be exercised.
Example: The Companies Act, 2013 contains 7 Schedules.
Schedules attached to a statute, forms part of it and must be read together with it for all purposes
of construction. But expressions in the schedule cannot control or prevail against the express
enactment.
(11) Punctuations: Commas, semi-colons, full stops etc. are also important in interpretation
of statute.
(12) Non Obstante Clause: Non obstante clause usually starts with the word ‘Notwithstanding
anything contained in…….’. Non obstante clause is employed to give overriding effect to
certain provisions over some contrary provisions that may be found in the same enactment or
some other enactments, which is to say to avoid the operations and effect of all contrary
provisions.
What are the external aids to interpretation of statute?
To find the true intention of the legislature, there exist many rules, principles and aids in
interpretation of statutes. Apart from the intrinsic aids, such as preamble and purview of the
act, the Court, can consider resources outside the Act, called the extrinsic or external aids.
Where the words of an Act are clear and unambiguous, no recourse to extrinsic matter, even if
it consists of the sources of the codification, is permissible.
Following are external aids used in interpretation of Statute:
(1) Dictionaries: When a word or expression is not defined in the Act itself, it is permissible
to refer to dictionaries to find out the general sense in which that word is understood in common
parlance. But courts must be careful because it is not necessary that dictionary meanings of a
word may be the true meaning in a particular context.
(2) Historical background: The Courts take recourse of such historical facts and surrounding
circumstances which existed at the time of passing of the Statutes and as may be necessary to
understand the subject matter of the statutes. Like any other external aid, the inferences from
historical facts and surrounding circumstances, must give way to the clear language employed
in the enactment itself.
(3) Parliamentary history: The Supreme Court, enunciated the rule of exclusion of
parliamentary history as in English Courts, but the court used this aid in resolving questions of
construction in many occasions. The court has now changed the view that legislative history
within circumspect limits may be consulted by courts in resolving ambiguities.
(4) Reference to other statutes: A statute must be read as a whole, as words are to be
understood in their context. Extension of this rule or context, permits reference to other statutes
in pari materia, i.e. statutes dealing with the same subject matter or forming part of the same
system. Viscount Simonds conceived it to be a right and duty to construe every word of a
statute in their context and he used the words in their widest sense including “other statutes
in pari materia”.
The phrase ‘pari materia’ is used in connection with two laws relating to the same subject
matter that must be analyzed with each other.
(5) Reference to reports of committees: The report of a committee on whose report an
enactment is based, can be looked into
“so as to see the background against which the legislation was enacted, the fact cannot be
ignored that the Parliament may, and often does, decide to do something different to cure the
mischief”.
So we should not be unduly influenced by the report. When the parliament has enacted a statute
as recommended by the report of a committee and there is ambiguity or uncertainty in any
provision of the statute, the court may have regard to the report for ascertaining the intention
behind the provision.
(6) Use of foreign decisions: Use of foreign decisions of countries following the same system
of jurisprudence as of India and rendered on statutes in pari material, has been permitted by
practice in Indian Courts. 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 Indian conditions where it is to be
applied.
(7) Statement of objects and reasons: The statement of objects and reasons as well as the
“Notes on clauses of the Bill” can be made use of in the interpretation of statutes, if the same
have been adopted by the Parliament without any changes in enacting the bill.
7. STRICT RULE OF INTERPRETATION: -
Strict Interpretation/Construction:
Strict interpretation or construction is a legal approach wherein ambiguous language is given
its exact and technical meaning, without considering equitable considerations or reasonable
implications beyond what is explicitly stated in the text. This method involves a narrow
interpretation of statutes, clauses, or other legal writings, relying solely on the plain meaning
of the words themselves, or what the meaning was at the time and place of their original
drafting. Also known as original intent or strict interpretation, it focuses solely on what is
written in the law, without delving into the intent of the lawmakers or the spirit of the law.
Key Points:
 Plain Meaning: The plain meaning or letter of the law is emphasized, without
considering extraneous factors.
  Original Intent: The focus is on the original intent of the lawmakers at the time of
drafting the law, rather than considering evolving societal norms or circumstances.
 Literal Interpretation: The words of the statute are interpreted in their ordinary and
literal sense, without resorting to judicial inference or speculation.
 Limitation of Judicial Interpretation: Judges are urged to refrain from drawing
inferences or implications from the statute beyond what is explicitly stated in the text.

A) INTERPRETATION OF PENAL STATUTES: Interpretation of penal statutes involves

applying a strict rule to ensure that individuals are not unfairly subjected to criminal liability
or penalties. This approach is crucial due to the severe consequences involved in criminal cases.
Courts adopt a narrow and literal interpretation, focusing solely on the language used in the
statute without considering extraneous factors such as legislative intent or spirit of the law.
Case Example: Commissioner of Customs (Import), Mumbai v. M/s Dilip Kumar and
Company & Ors (2018): In this landmark case, the Supreme Court of India emphasized the
importance of strict interpretation in penal statutes, particularly those related to taxation. The
court reiterated that penal statutes, which curtail an individual's rights or liberty, must be
construed strictly to prevent arbitrary or discretionary decision-making. It held that any
ambiguity in such statutes should be resolved in favor of the subject, providing a safeguard
against potential abuse of power by the legislature.
Furthermore, the rule of lenity, a fundamental principle of criminal law, dictates that any
ambiguity in a criminal statute should be resolved in favor of the defendant. This ensures that
individuals are not unjustly penalized for conduct that does not clearly fall within the scope of
the law.
b) Interpretation of Taxing Statutes:
Similarly, taxing statutes require a strict approach to prevent undue financial burden on
taxpayers and to maintain the integrity of the tax system. Tax laws are often complex, and any
ambiguity in their interpretation can have significant consequences for individuals and
businesses. Therefore, courts apply a strict rule of interpretation to tax statutes, focusing
exclusively on the language used in the statute itself.
Case Example: IRC v. Fisher's Executors (1946): In this landmark case, the United States
Supreme Court reaffirmed the principle of strict interpretation in taxing statutes. The court held
that taxation is a matter of legislative policy, and any ambiguity in tax laws should be resolved
in favor of the taxpayer. It emphasized that taxes cannot be imposed on individuals without
clear and explicit authority from the legislature.
Moreover, the burden of proof rests with the revenue authorities to establish the applicability
of taxes, exemptions, or deductions. Any ambiguity or uncertainty in the language of the tax
statute should be construed in favor of the taxpayer, ensuring that they are not unfairly burdened
with taxes beyond what is authorized by law.
8. Subsidiary rules of interpretation
the subsidiary rules of interpretation, providing case law examples and further elaboration:
 1. Same Word, Same Meaning: This principle emphasizes consistency in the
interpretation of terms used within a statute. Courts presume that when lawmakers use
the same word or phrase in different sections of a statute, they intend for it to have the
same meaning throughout unless context suggests otherwise.
Example: In the case of Jmaiff v. The Grand Forks Rural Fire Protection District (1990), the
court interpreted the term "property" consistently throughout the statute, ensuring that it carried
the same meaning in all relevant sections.
2. Use of Different Word: When lawmakers use different words or phrases within the
same statute, courts presume that each term has a distinct meaning, even if they seem
similar. This presumption helps prevent redundancy and ensures precision in legal
drafting.
Example: In Shri Ishar Alloy Steels Ltd v. Jayaswalas Neco Ltd. (2001), the Supreme Court of
India interpreted different phrases in the Income Tax Act of 1922 ("at the end of the previous
year" and "in the course of such previous year") differently, highlighting the importance of
discerning unique meanings for distinct terms.
3. Rule of Last Antecedent: This rule states that words or phrases in a statute typically
modify or apply to the words or phrases closest to them, rather than those further away.
However, this rule may be overridden by contextual factors indicating a different
interpretation.
Example: In State of Madhya Pradesh v. Shobharam and Ors. (1966), the court examined the
placement of a comma in a statute to determine the scope of its application, illustrating how
punctuation can influence the rule of last antecedent.
4. Non-Obstante Clause: A non-obstante clause, often beginning with the term
"notwithstanding," indicates that the provision following it prevails over any conflicting
provisions within the same statute. This clause ensures clarity and resolves conflicts
within the law.
Example: The presence of a non-obstante clause in a statute was analyzed in Kamta Prasad
Aggarwal v. Executive Engineer, where the court gave precedence to the provision following
the non-obstante clause despite conflicting sections elsewhere in the law.
5. Legal Fiction: Legal fictions allow courts to assume or create facts to achieve just
outcomes or facilitate the application of legal rules. However, their use should be
judicious and consistent with legal principles.
Example: A classic example of a legal fiction is the notion that English courts "declare" rather
than "create" common law. In R v. Sussex Justices, ex parte McCarthy, the court invoked the
legal fiction of "bias" to ensure a fair trial, highlighting its role in promoting justice.
6. Mandatory and Directory Provisions: Mandatory provisions must be strictly adhered
to, while substantial compliance is acceptable for directory provisions. Failure to
comply with mandatory requirements typically leads to nullification, while non-
compliance with directory provisions does not invalidate the act.
Example: The consequences of non-compliance with mandatory provisions were examined in
Limitation Act cases, where failure to adhere to prescribed time limits for legal proceedings
resulted in dismissal.
7. Consequences of Non-Compliance: Non-compliance with statutory requirements
often results in specific consequences outlined in the law. While failure to comply with
mandatory provisions typically leads to nullification, non-compliance with directory
provisions may not invalidate the action.
Example: In State of Madhya Pradesh v. Shobharam and Ors., non-compliance with certain
procedural requirements led to the dismissal of a legal claim, demonstrating the consequences
of non-compliance in statutory interpretation.
8. Conjunctive and Disjunctive Words 'or' and 'and': Courts interpret the words "or"
and "and" based on legislative intent, with "and" typically being conjunctive and "or"
being disjunctive by default. However, legislative intent may override this default
interpretation.
Example: The significance of interpreting conjunctive and disjunctive words based on
legislative intent was illustrated in Kamta Prasad Aggarwal v. Executive Engineer, where the
court analyzed the context to determine the intended meaning of these terms.
By employing these subsidiary rules of interpretation alongside primary rules, courts ensure
that statutes are interpreted accurately and in accordance with legislative intent, promoting
fairness and consistency in legal outcomes.

9. LEGAL MAXIMS:
What is noscitur a sociis?
Noscitur a sociis is a Latin legal maxim that means it is known by its associates or it is known
from its companions. In the context of legal interpretation, this principle is used to determine
the meaning of a particular word or phrase in a statute or legal document based on the words
or phrases that surround it or are associated with it.
Here’s how it works:
 Contextual Interpretation: When multiple words or phrases are used together in a
legal provision and one of those words or phrases is ambiguous or unclear in its
meaning, noscitur a sociis suggests that the meaning of that word should be determined
by looking at the context provided by the other words or phrases in the same provision.
 Restriction or Clarification: The principle helps to clarify or restrict the meaning of
the ambiguous word by considering it in the context of the surrounding words. In other
words, the meaning of the unclear word is influenced or limited by the words it is
associated with.
 Avoiding Ambiguity: The goal of applying noscitur a sociis is to avoid ambiguity in
legal texts by interpreting the words in a way that makes sense within the overall context
of the statute or document.
For example, if a legal provision refers to vehicles, including cars, trucks and other vehicles,
and the term other vehicles is ambiguous, noscitur a sociis would suggest that other vehicles
should be interpreted in the context of the specific examples given (cars and trucks) and should
not include, for instance, bicycles or boats.
What is Ejusdem generis?
Ejusdem generis is a Latin legal principle that means of the same kind or of the same nature.
In the context of legal interpretation, this principle is used to interpret ambiguous or general
words in a statute or contract based on the specific words or phrases that precede them.
Here’s how it works:
 General vs. Specific Words: When a provision or clause in a legal document includes
a list of specific words or phrases followed by a more general or ambiguous term,
ejusdem generis suggests that the general term should be interpreted to be of the same
kind or nature as the specific words listed.
 Restriction or Clarification: The principle helps to restrict or clarify the meaning of
the ambiguous term by considering it in the context of the specific examples provided.
In essence, the general term takes on the characteristics of the specific terms that
precede it.
 Avoiding Overly Broad Interpretations: The purpose of applying ejusdem generis is
to prevent overly broad interpretations of the general term that could lead to unintended
consequences or loopholes in the legal text.
For example, if a contract clause states that employees are prohibited from bringing animals,
including dogs, cats and other animals into the workplace and the term other animals is
ambiguous, ejusdem generis would suggest that other animals should be interpreted to be of
the same kind as the specific animals mentioned (i.e., pets) and it would not include, for
instance, farm animals or exotic wildlife.