Name: -

Umar HASHMI
Class: -
BBA. LL.B.
SEMESTER:-
VIII
Roll No.: -
05214703520
Subject: -
Interpretation
of Statutes
MAIMS
 Dr. Jaishri Laxmanrao Patil V/s The Chief
Minister & Anr.

Summary of the Judgment:

The case discussed in the provided judgment is Civil Appeal No. 3123
of 2020, involving Dr. Jaishri LaxmanRao Patil as the appellant and the
Chief Minister & Anr. as the respondents. The judgment was delivered
by Justice L. Nageswara Rao in the Supreme Court of India. The
judgment deals with various questions related to the interpretation of
Article 342 A of the Constitution of India, particularly regarding the
identification and inclusion of socially and educationally backward
classes.
Justice L. Nageswara Rao, in his judgment examines the opinions of
Justice Ashok Bhushan and Justice S. Ravindra Bhat regarding various
questions posed before the court. While there is unanimity on certain
issues, particularly questions 1, 2, and 3, there is a divergence of
opinion on questions 4, 5, and 6, specifically related to the
interpretation of Article 342 A of the Indian Constitution. Regarding
questions 1, 2, and 3, Justice Rao aligns himself with the opinion of
Justice Ashok Bhushan, as the issues have been exhaustively addressed
by him. However, on questions 4, 5, and 6, pertaining to the
interpretation of Article 342 A, Justice Rao diverges from Justice
Bhushan's conclusion and agrees with the opinion of Justice S.
Ravindra Bhat.
Article 342 A of the Constitution of India deals with the specification
of socially and educationally backward classes by the President, in
consultation with the Governor of a State or Union territory. The article
empowers the Parliament to include or exclude such classes from the
Central List through legislation.
Justice Rao discusses the principles of constitutional interpretation,
emphasizing the importance of adhering to the plain meaning of the
text while also considering the broader purpose and intent behind the
provisions. He references various legal authorities and precedents to
underscore the significance of interpreting constitutional provisions in
accordance with their explicit language.
The judgment scrutinizes the language of Article 342 A and its context
within the constitutional framework. It emphasizes that the primary
rule of construction is literal interpretation unless the language is
ambiguous or leads to absurd results. The judgment rejects the
contention that extrinsic aids such as parliamentary committee reports
should override the clear language of the Constitution.
Justice Rao concludes that Article 342 A unequivocally mandates that
only those backward classes specified in the public notification issued
by the President shall be considered socially and educationally
backward classes for constitutional purposes. He dismisses arguments
suggesting a narrower interpretation of the term "Central list," asserting
that such an interpretation would undermine the intent and scope of the
provision.
In summary, the judgment affirms that Article 342 A must be construed
in accordance with its plain language, which establishes a singular list
of socially and educationally backward classes specified by the
President. It underscores the importance of adhering to the
constitutional text while considering the broader legislative purpose
and intent.

Discussion of the Rule of Interpretation:

Justice Rao employs several rules of interpretation in reaching his
conclusion regarding the interpretation of Article 342 A. Let's delve
into each of these rules extensively:
1. Plain Meaning/Literal Interpretation:
Justice Rao emphasizes the importance of interpreting the Constitution
based on its plain meaning. He asserts that the intention of the
legislature must primarily be ascertained from the language used in the
statute itself. This rule guides Justice Rao's analysis of Article 342 A,
wherein he meticulously examines the language of the provision to
derive its plain meaning.
Justice Rao also referred the Justice Ashok Bhushan Opinion that the
elementary principle of interpreting the Constitution or a statute is to
look into the words used in the statute and when the language is clear,
the intention of the legislature is to be gathered from the language used.
He further opined that aid to interpretation is resorted to only when
there is some ambiguity in words or expression used in the statute.
Justice Bhushan in State (NCT of Delhi) v. Union of India held that
the constitutional interpretation has to be purposive taking into
consideration the need of the times and constitutional principles. The
intent of framers of the Constitution and object and purpose of
constitutional amendment always throw light on the constitutional
provisions but for interpreting a particular constitutional provision, the
constitutional scheme and the express language employed cannot be
given a go-by. He further held that the purpose and intent of the
constitutional provisions have to be found from the very constitutional
provisions which are up for interpretation.

2. Purpose and Object of the Legislation:

In line with the rule of interpreting legislation in accordance with its
purpose and object, Justice Rao seeks to discern the legislative intent
behind Article 342 A. He emphasizes the need to understand the
purpose for which the provision was inserted into the Constitution. By
analyzing historical context, parliamentary debates, and committee
reports, Justice Rao attempts to elucidate the underlying objectives of
Article 342 A.
Justice Rao referred the House of Lord Case for explaining the
purposive rule of interpretation i.e., Aron Soloman v. Soloman & Co.
A construction which furthers the purpose or object of an enactment is
described as purposive construction. A purposive construction of an
enactment is one which gives effect to the legislative purpose by (a)
following the literal meaning of the enactment where that meaning is
in accordance with the legislative purpose or (b) applying a strained
meaning where the literal meaning is not in accordance with the
legislative purpose.24 If that is the case, there is no gainsaying that
purposive interpretation based on the literal meaning of the enactment
must be preferred.
3. External Aids to Interpretation:
While acknowledging the relevance of external aids such as
parliamentary debates and committee reports, Justice Rao exercises
caution in their utilization. He emphasizes that such aids should only
be relied upon when the legislative language is ambiguous or unclear.
In his analysis, Justice Rao evaluates the deliberations of the Select
Committee and parliamentary debates to shed light on the intent behind
Article 342 A.
In his words Justice Rao stated that I am convinced that there is no
reason to depart from the text which is in clear terms and rely upon the
legislative history to construe Article 342 A contrary to the language. I
am not persuaded to agree with the submissions of the learned Attorney
General and the other counsel for the States that Article 342 A has to
be interpreted in light of the Select Committee report and discussion in
the Parliament, especially when the legislative language is clear and
unambiguous.
4. Harmonious Construction:
Justice Rao adopts a harmonious construction approach in interpreting
Article 342 A. He endeavors to reconcile the different provisions of the
Constitution to ensure coherence in the legal framework. By aligning
Article 342 A with other relevant constitutional provisions, Justice Rao
aims to arrive at an interpretation that is consistent with the overall
structure and objectives of the Constitution.
5. Role of Judicial Discretion:
In exercising judicial discretion, Justice Rao acknowledges the need to
balance adherence to the literal meaning of the provision with the
pursuit of legislative intent. While recognizing the importance of literal
interpretation, he acknowledges that departures from literal meaning
may be warranted in certain circumstances where the legislative
purpose is clear. Therefore, Justice Rao exercises judicial discretion
judiciously in interpreting Article 342 A.
Through the application of these rules of interpretation, Justice Rao
provides a thorough and reasoned analysis of Article 342 A,
culminating in a conclusion that aligns with Justice Bhat's
interpretation.

Conclusion:
In conclusion, the analysis of Justice L. Nageswara Rao's judgment in
Civil Appeal No. 3123 of 2020 offers valuable insights into the intricate
dynamics of statutory interpretation within the Indian legal landscape.
By meticulously applying various rules of interpretation, including
literal interpretation, legislative intent, purposive interpretation,
contextual analysis, and harmonious construction, Justice Rao
navigates the complexities of Article 342 A to elucidate its meaning
and implications. This paper serves as a comprehensive exploration of
the interpretative process, shedding light on the nuanced reasoning and
legal principles guiding judicial decision-making in matters of
constitutional significance.