Beneficial Construction of Statute

The Principle of Beneficial Construction of Statute has an important place in

Interpretation Statutes. Generally, every Act has been enacted for the protection of
interests of one or the other class. In such a situation, it is essential that it should be
interpreted in such a way that such interest one protected. This purpose has led to
the origin of The Principle of Beneficial Construction of Statute.

The general rule of the statute is that if a word used in the statute excludes certain
cases in its common meaning, it should not be forced unnecessarily to include
those cases. An exception to this rule is that when the main objective of the statute
is not achieved by excluding those cases then the word may be interpreted on the
basis of the case requires.

This rule of interpretation will benefit individuals. Whenever there is an ambiguity

or when that would take the benefit away from the individual, so the meaning
which prevails over the benefit to the individuals should be adopted.

The courts should be generous towards the persons to whom benefits are conferred
by the statute. Here it involves the judges to give the widest meaning to the statute
in order to protect the interest of the parties, if you look into certain statutes the
main purpose is to benefit and protect the interest of the person, for example,
Industrial Disputes Act, Consumer Protection Act, Juvenile Justice Act and all
labour-related laws. Provision is capable of giving two meanings where one would
preserve the benefit and another.

Hindustan Level Ltd v Ashok Vishnu Kate- In this case, the court held that in a
case which is related to the prevention of unfair labour practices it should be made
completely in accordance with the labour point of view as they are benefitting
people here and while interpreting Social Welfare Legislation also they should
consider the benefitting people of the society.

Noor Saba Khatoon v. Mohammad Quasium- The supreme court held that the
rights of maintenance of children below two years old and the mother
under Section 125 of the code of civil procedure 1973 are independent of each
other and any other and subsequent legislature regarding maintenance of children
below two year and mother that maybe Muslim women (Protection of rights on
Divorce) Act, 1986 could not affect the same in absence of clear provision to the
effect.

Kanailal v/s Paramnidhi (AIR. 1957 S.C. 907)—Supreme Court decided that
Calcutta Thika Tenant Act, 1949 is a Beneficial Construction, hence it should be
interpreted in such a way as would not harm the interests of Thika Tenants.

Alembic Chemical Works v/s Workmen (AIR. 1961 S.C. 647)—Supreme Court
decided that the factories act being a beneficial legislation, it has to be construed in
favor of the employer or workmen of factories.

State of Madhya Pradesh v/s Galla Tilhan Vyapari Sangh (A.I.R. 1977 S.C. 2208)
—Supreme Court called the Madhya Pradesh Krishi -Upaj Mandi Adhiniyam,
1972 as a beneficial construction and said that its object is to benefit the principle
by limiting the profits of the middle-man, hence it should be construed according
to the object.

Where any Act has been framed to protect the interest of two opposite classes,
there should be interpreted in such a way that both the classes interest remains
safe.

Mani Subrot Jain v/s Rajaram (A.I.R. 1980 S.C. 299)— The Supreme Court while
considering the rent control legislation as a beneficial construction stated that it
should be so construed that the object of act to provide residence should be
fulfilled.

Ms Rehbar Productions Pvt. Ltd. v/s Rajendra K. Tandon (A.I.R. 1998 S.C.
1827) is a good example on this topic. Supreme Court decided in it that the Rent
Control Act is a beneficial Law as well as a prohibition Law. Hence this should be
interpreted in such a way that a balance remains between the rights of the
landowner and liabilities of the tenant.
where the language of Statute is clear and unambiguous. There it should have
literal or grammatical interpretation. But where the language used in Statute leads
to more than one meaning, it should be given that meaning which can protect the
interest of that class for which that Statute is enacted. This is the rule of Beneficial
Construction. In other words, it is said that while interpreting the interests of that
class or group cannot be ignored for class or group that Statute has been framed.

Mahadev Lal v/s State of West Bengal (A.I.R 1960S C. 936)-Supreme Court said
that if the common purpose of a Statute is to provide benefit to a particular class of
persons, and that Statute contains such contradictory provisions provide benefit to
a certain specific class and other are harmful, then that provision shall be accepted
‘, which provide benefit to the specific class. In case of interpretations leading to a
different meaning that interpretation shall be accepted which is in accordance to
the interests of particular class.