MUNICIPAL CORP. DELHI VS MD.

YASIN

"Words and phrases take colour and character from the context and the times and speak

differently in different contexts and times" Municipal Corp, Delhi v Mohd Yasin, (1983) 3
SCC 229,

RAMAVATAR BUDHAIPRASAD V ASSISTANT SALES TAX OFFICER, AIR 1961

SC 1325

In a case before the Supreme Court, the question was as to the meaning of the word
"vegetables" as it occurred in the CP and Berar Sales Tax Act, 1947 as amended by Act 16 of
1948, whether it included betel leaves or not. Although the word in natural history and
according to dictionary meaning is comprehensive enough to include betel leaves, the Supreme
Court held that "being a word of everyday use it must be construed in its popular sense,
meaning that sense which people conversant with the subject matter with which the statute is
dealing would attribute to it" and so the word was construed to denote those classes of vegetable
matter which are grown in kitchen gardens.

H.P. KHANDELWAL VS STATE OF UP 1955

In this case the learned Standing Counsel contends that the effect of the insertion of a comma
after the word 'Legislature' in U. P. Land Acquisition (Rehabilitation of Refugees) Act, 1948
is to limit the application of the words "having power to make such a law.

The court however do not think that learned counsel's contention is well-founded, for the court
was of opinion that the comma after the word 'Legislature' is merely a substitute for the word
'or', and that the concluding words of the definition apply no less to an enactment passed by a
Legislature than to one made by an authority or person.
SARAH MATHEW V INSTITUTE OF CARDIO VASCULAR DISEASES, (2014)

In Sarah Mathew v. Institute of Cardio Vascular Diseases, it was held that sectional
headings have a limited role to play in the construction of statutes. The heading of Ch.
XXXVI, Cr.P.C. is not an indicator that the date of taking cognizance is the date on which
limitation period commences.

Section 468 (1) of the CrPC provides that no court shall take "cognizance" of an offence of the
category specified in sub-section (2) after the expiry of the period of limitation.

In this case it was held that for the purposes of limitation under section 468(1), the relevant
date is the date of filing complaint or institution of prosecution, and not the date on which the
Magistrate takes cognizance.

UOI VS NATIONAL FEDERATION OF BLIND (2013)10 SCC 772

Section 33 of the Persons with Disabilities (Equal Opportunities, Protection of Rights and Full
Participation) Act, 1995, which is titled "Reservation of posts", and provides that "every
appropriate Government shall appoint in every establishment such percentage of vacancies not
less than three
percent for persons or class of persons with disability…". It was contended that the reservation
for persons with disabilities is post-based, and not vacancy-based, relying on the heading of
section 33. However, the Supreme Court held that it is clear from the simple and unambiguous
language of section 33 that the computation of reservation has to be against the total number
of vacancies in the establishment, and not against the "identified posts", as the heading of a
section will not play a crucial role when the language of the section is clear and unambiguous.

N.C. DHOUNDIAL V. UNION OF INDIA

In N.C. Dhoundial v. Union of India, it was held that “Heading” can be relied upon to clear
the doubt or ambiguity in the interpretation of the provision and to discern the legislative intent.
GUNTAIAH & ORS VS HAMBAMMA & ORS ON 22 JULY, 2005

Marginal notes in an Indian statute, as in an Act of Parliament, cannot be referred to for the
purpose of construing the statute.

MOHAMMAD SHABBIR V. STATE OF MAHARASHTRA

 Interpretation of Section 27 of the Drugs and Cosmetics Act, 1940 was in question.
 This provision says that whoever ‘manufactures for sale, sells, stocks or exhibits for
sale or distributes’ a drug without licence would be liable to punishment.
 The Supreme Court held that mere stocking of a drug is not an offence and an
offence is made out only when stocking is for sale.
 There is no comma after the word ‘stocks’ which means that the words ‘stocks or
exhibits’ are both qualified by the words ‘for sale’ used thereafter.

SAMA ALANA ABDULLA VS THE STATE OF GUJARAT ON 16 NOVEMBER, 1995

The High Court held that the word 'secret' in Clause (c) of Official Secrets Act, 1923 qualifies
only the words "official code or pass word" and not "any sketch, plan, model, article or note or
other document or information". The reason given by the High Court is that after the phrase
"any secret official code or pass word", there is a comma and what follows is thus not intended
to be qualified by the word 'secret'.
SHAMBU NATH MEHRA VS THE STATE OF AJMER ON 12 MARCH

Illustrations cannot have the effect of modifying the language of the section and they
cannot either curtail or expand the ambit of the section which alone forms the
enactment.

ALI M.K. AND ORS VS STATE OF KERALA AND ORS

A proviso to a section cannot be used to import into the enacting part something which is not
there, but where the enacting part is susceptible to several possible meanings it may be
controlled by the proviso.

UNION OF INDIA & ORS VS DILEEP KUMAR SINGH

In Union of India v. Dileep Kumar Singh, it has been held that though a proviso does not
travel beyond the provision to which it is appended, golden rule is to read the whole Section,
inclusive of the proviso in such manner that they mutually throw light on each other and result
in a harmonious construction.

S. SUNDARAM PILLAI, ETC VS V.R. PATTABIRAMAN

In S. Sundaram v. V.R. Pattabhiraman, the Supreme Court observed that it is now well
settled that an explanation added to a statutory provision is not a substantive provision in any
sense of the term but as the plain meaning of the word itself shows it is merely meant to explain
or clarify certain ambiguities which may have crept in the statutory provision.
The object of an explanation to a statutory provision is:

 to explain the meaning and intendment of the Act itself;

 where there is any obscurity or vagueness in the main enactment, to clarify the same
so as to make it consistent with the dominant object which it seems to subserve;
 to provide additional support to the dominant object of the Act in order to make it
meaningful and purposeful.

THE DOMINION OF INDIA AND ANOTHER VS SHRINBAI A. IRANI AND

ANOTHER ON 14 MAY, 1954

There should be a close approximation between the non obstante clause and the operative part
of the section, the non obstante clause need not necessarily and always be co-extensive with
the operative part, so as to have the effect of cutting down the clear terms of an enactment.

THE STATE OF BOMBAY VS R. M. D. CHAMARBAUGWALA ON 9 APRIL, 1957

Section 2(1)(d) of the Bombay Lotteries and Prize

Competitions Control and Tax Act, 1948, which reads: "prize competition includes: (1)
Crossword Prize Competition, (2) Missing Word Prize Competition, (3) Picture Prize
Competition, (4) Number Prize Competition, or (5) any other prize competition, for
which solution is or is not prepared beforehand by the promoters or for which the
solution is determined by lot or chance". The qualifying clause in the 5th item beginning
with "for which the solution" was construed by the Supreme Court to apply to all the five
items and it was observed: "There is grammatically no difficulty in reading the
qualifying clause as lending colour to each of those items."
ICICI BANK & ANR VS MUNICIPAL CORPORATION OF GREATER ... ON 4
AUGUST, 2005

In the case of Municipal Corporation of Greater Bombay (supra), Section 328A was not at all
interpreted by this Court. For the case to be a binding precedent, fundamental requirement
would be, that the law pronounced should result from the issues raised before the Court between
the parties and argued on both sides. In the matter of Municipal Corporation of Greater Bombay
the definition of `sky-sign' under Section 328 came up for consideration. In reaching the
conclusion that the huge metallic board exhibited by BPC Petrol Bunk on a pole with the name
of the Company and its symbol (Shell symbol) was a sky-sign, this Court laid emphasis on the
expression "in the nature of an advertisement" occurring in the definition of `sky-sign' in
Paragraph 10 which expression is not to be found in Section 328-A. While interpreting Section
328 and construing the words `in the nature of an advertisement, announcement and direction',
this Court held that the advertisement need not necessarily be only or solely for commercial
exploitation whereas Section 328A of the Act speaks about `advertisement' alone and not `in
the nature of an advertisement'.

SOUTHERN PETROCHEMICAL ... VS ELECTRICITY INSPECTOR AND ... ON 15

MAY, 2007

Once the aforementioned conclusion is arrived at, it would not be necessary to construe the
proviso appended to Sub-section (1) of Section 20 of Consumption or Sale of Electricity Act,
2003 in its own language. Proviso, as is well known, has four functions, as has been noticed by
this Court in S. Sundaram Pillai v. V.R. Pattabiraman, [(1985) 1 SCC 591 in the following
terms: "
(1) qualifying or excepting certain provisions from the main enactment;

(2) it may entirely change the very concept of the intendment of the enactment by insisting on
certain mandatory conditions to be fulfilled in order to make the enactment workable;

(3) it may be so embedded in the Act itself as to become an integral part of the enactment and
thus acquire the tenor and colour of the substantive enactment itself; and

(4) it may be used merely to act as an optional addenda to the enactment with the sole object
of explaining the real intendment of the statutory provision."

STATE OF MADRAS V. A VAIDYANATH IYER, AIR 1958 SC 61

A matter concerning the admission and disposal of criminal appeals has to be dealt with in
terms of Code of Criminal Procedure and not outside those provisions;

In Art. 136 the use of the words " Supreme Court may in its discretion grant special leave to
appeal from any judgment, decree, determination, sentence or order in any cause or matter
passed or made by any court or tribunal in the terri- tory of India " show that in criminal matters
no distinction can be made as a matter of construction between a judgment of conviction or
acquittal.

TATA ENGINEERING AND LOCOMOTIVE COMPANY LTD. V. GRAM

PANCHAYAT PIMPERIVERGHE AIR 1976 SC

In construing the word "houses" in section 89 of the Bombay Village

Panchayats Act, 1933, the Supreme Court relied upon the rules made in 1934 which
used the word "building" in place of "houses" as one of the aids for holding that the
word "houses" as used in the Act was not limited to dwelling houses but included all
buildings whether used for residence or commercial purposes.

YAKUB MENON CASE

In Yakub Abdul Razak Memon v. State of Maharashtra the supreme court held that the conflict
between the provisions of two statutes has to be resolved by references to purpose and policy
underlying two enactments. The Court must take into consideration principal subject matter of
statute and particular perspective in order to determine whether a statute is special or general
one.

PANDIT M.S.M. SHARMA V. KRISHNA SINHA

It was held that the privileges enjoyed by a House of Parliament and the state legislature under
Art. 105(3) and 194(3)] respectively are not subject to Art. 19(1)(a), and therefore, the House
was entitled to prohibit the publication of any report of its debates or proceedings even if the
prohibition contravenes the Fundamental Right of Speech and Expression of the publisher. The
conflict between these provisions should be resolved with the help of 'harmonious construction'
of the two provisions, and Art. 19(1)(a) being of a general nature must yield to Art. 105(3) [or
Art. 194(3)].

VINAY TYAGI V. IRSAD ALI, 2013 5 SCC 762

The Supreme Court has held that though there is no specific requirement under section
173(8) of the CrPC, 1973, to conduct "further investigation" or file "supplementary
report" with the leave of the court, the investigating agencies have not only understood
but also adopted it as a legal practice to seek permission of the courts to conduct
"further investigation" and file "supplementary report", and will therefore have to be read
into, and is a necessary implication of section 173(8). The doctrine of contemporanea
expositio will fully come to the aid of such interpretation as matters which are
understood and implemented for a long time and such practice that is supported by
law should be accepted as part of the interpretative process.

MANOHAR LAL SHARMA VS UNION OF INDIA ON 6 FEBRUARY, 2014

Further, an interpretation to a statute received from contemporary authority is not binding upon
the courts and may have to be disregarded if such interpretation is clearly wrong. Section 5 of
the Mines and Minerals (Regulation and Development) Act, 1957, provides that the State
Government shall not grant a reconnaissance permit, prospecting licence or mining
lease except with the previous approval of the Central Government. The Supreme Court
held that the process evolved by the Central Government for allocation of coal blocks
for captive use, whereby applications were made directly to, and allocation letters
issued directly by, the Central Government, leaving virtually no power with the State
Government to objectively consider the application, has significantly and effectively
reversed the scheme provided in the 1957 Act, and was hence contrary to law and not
binding on the Court.

MOHD. HANIF QUARESHI V. STATE OF BIHAR, 1959 SCR 629 : AIR 1958 SC 731

In the case of Mohd. Hanif Quareshi v. State of Bihar, 1959 SCR 629 : AIR 1958 SC 731,
which was decided by a 5-judge Constitution bench of the Supreme Court, the challenge was
to three laws banning the slaughter of certain animals, passed by the States of Bihar, Uttar
Pradesh and Madhya Pradesh. In Bihar, the Bihar Preservation and Improvement of Animals
Act, 1956, was introduced which imposed a total ban on the slaughter of all categories of
animals belonging to the species of bovine cattle. In Uttar Pradesh, the Uttar Pradesh
Prevention of Cow Slaughter Act, 1955, was enacted which also imposed a total ban on the
slaughter of cows and her progeny which included bulls, bullocks, heifers and cows. In the
State of Madhya Pradesh, it was the CP and Berar Animal Preservation Act, 1949, which was
amended and applied and it imposed a total ban on the slaughter of cows and female calf of a
cow, while the male calf of a cow, bull, bullock, buffalo (male or female, adult or calf) could
be slaughtered only on obtaining a certificate.

Following three grounds for challenging the constitutional validity of these 3 laws were
discussed in the above judgment:

1. that the total ban offended the religion of the Muslims as the sacrifice of a cow on a
particular day is enjoined or sanctioned by Islam;
2. that such ban offended the fundamental right guaranteed to the kasais (butchers)
under Article 19(1)(g) of the Constitution and was not a reasonable and valid
restriction on their right; and
3. that a total ban was not in the interest of the general public.

The Supreme Court held as under:

1. A total ban on the slaughter of cows of all ages and calves of cows and calves of
she-buffaloes, male or female, was quite reasonable and valid and is in consonance
with the directive principles laid down in Article 48;
2. A total ban on the slaughter of she-buffaloes or breeding bulls or working bullocks
(cattle as well as buffaloes) as long as they are capable of being used as milch or
draught cattle was also reasonable and valid;
3. A total ban on slaughter of she-buffaloes, bulls and bullocks (cattle or buffalo) after
they ceased to be capable of yielding milk or of breeding or working as draught
animals could not be supported as reasonable in the interests of the general public,
and was invalid.

The above-mentioned first ground of challenge (i.e., that the total ban offended the religion of
the Muslims as the sacrifice of a cow on a particular day is enjoined or sanctioned by Islam)
was rejected by the Constitution bench of the Supreme Court due to the meagre materials
placed before the Court and the bald allegations and denials made by the parties. It was noticed
that many Muslims do not sacrifice cows on BakrI’d day. The Supreme Court further observed
as under:
“It is part of the known history of India that the Moghul Emperor Babar saw the wisdom of
prohibiting the slaughter of cows as and by way of religious sacrifice and directed his son
Humayun to follow this example. Similarly, Emperors Akbar, Jehangir and Ahmad Shah, it is
said, prohibited cow slaughter. Nawab Hyder Ali of Mysore made cow slaughter an offence
punishable with the cutting of the hands of the offenders. Three of the members of the
Gosamvardhan Enquiry Committee set up by the Uttar Pradesh Government in 1953 were
Muslims and concurred in the unanimous recommendation for total ban on slaughter of cows.
We have, however, no material on the record before us which will enable us to say, in the face
of the foregoing facts, that the sacrifice of a cow on that day is an obligatory overt act for a
Mussalman to exhibit his religious belief and idea. In the premises, it is not possible for us to
uphold this claim of the petitioners.”

Moreover, the challenge to the constitutional validity of the said laws on the basis of the right
to equality under Article 14 was also clearly rejected by the Supreme Court.

The question whether the restrictions permissible under clause (6) of Article 19 of the
Constitution may extend to “total prohibition” [on the contended fundamental right of the
butchers to slaughter animals of their liking or in which they were trading] was treated by
Supreme Court as a vexed question and was left open without expressing any final opinion
since the Supreme Court decided to concentrate on the issue as to whether the restriction was
at all reasonable in the interests of the general public, irrespective of the fact whether it could
be held to be partial or total.

After considering a lot of documentary evidence, the Supreme Court arrived at certain findings
of fact. The court opined that cow progeny ceased to be useful as a draught cattle after a certain
age and they, although useful otherwise, became a burden on the limited fodder available
which, but for the so-called useless animals, would be available for consumption by milch and
draught animals. The Court also noted that the response of the States in setting
up gosadans (protection homes for cows and cow progeny) was very poor. On the basis of
these facts, the Court concluded that in spite of there being a presumption in favour of the
validity of the legislation and respect for the opinion of the legislatures as expressed by the
three impugned laws, they were inclined to hold that a total ban of the nature imposed could
not be supported as reasonable in the interests of the general public.
DR. M. ISMAIL FARUQUI ETC, MOHD. ... VS UNION OF INDIA AND OTHERS ON
24 OCTOBER, 1994

White paper issued by the Government detailing the facts leading to enactment of a
statute is also admissible for understanding the background when the court is called
upon to interpret and decide the validity of the statute. Extensive reference was made
by the Supreme Court to the white paper for understanding the background of the Ram
Janmabhumi Babri Masjid dispute in deciding the reference made under Article 143 and
the constitutionality of the Acquisition of Certain Areas at Ayodhya Act, 1993.

SHASHIKANT LAXMAN KALE AND ANR VS UNION OF INDIA AND ANR ON 20

JULY, 1990

It has been held that an explanatory memorandum is usually not an accurate

guide of the final Act. While interpreting explanation (baa) to section 80HHC of the
Income-tax Act, 1961, the Supreme Court has held that it is not necessary to refer to
the explanatory memorandum when the language of the provision was clear. The court
held that only 90% of receipts by way of brokerage, commission, interest, rent, charges
or any other receipt of a similar nature included in such profits, computed under the
head "Profits and Gains of Business or Profession", could be deducted under
explanation (baa), and not 90% of any of the aforesaid receipts which are allowed as
expenses, and therefore not included in the profits of business of the assessee.

The distinction between the purpose or object of an enactment and the legislative
intention governing it is that the former relates to the mischief to which the enactment is
directed and its remedy, while the latter relates to the legal meaning of the enactment

The court still sometimes, like the English courts, makes a distinction between use of a
material for finding the mischief dealt with by the Act and its use for finding the
meaning of the Act.
CIT ANDHRA PRADESH V JAY LAKSHMI RICE AND OIL MILLS
CONSTRUCTION COMPANY,AIR 1991

It was held in CIT, AP v Jayalakshmi Rice and Oil Mills Contractor Co,65. that the
report of the special committee which had been appointed by the Government of India
to examine the provisions of the Bill which later became the Partnership Act cannot be
admitted for interpreting the provisions of the Act.

RAGHUNATH RAI BAREJA AND ANOTHER VS PUNJAB NATIONAL BANK AND

OTHERS

The court in this case was of opinion that the literal rule applies, and the other rules have no
application to interpreting Section 31 (only suits or other proceeding pending before the Court
immediately before the establishment of the Tribunal under the Act, stand transferred to the
Tribunal) of RDB Act i.e Recovery of debts and Bankruptcy Act 1993, since the language
of Section 31 is plain and clear, and cannot be said to be ambiguous or resulting in some
absurdity.

M/S. SONIC SURGICAL VS NATIONAL INSURANCE COMPANY LTD ON 20

OCTOBER, 2009
The court held that an interpretation has to be given to the amended Section 17(2) (b) of the
Consumer protection Act 1986, which does not lead to an absurd consequence. Court was of
the opinion that the expression 'branch office' in the amended Section 17(2) would mean the
branch office where the cause of action has arisen. No doubt this would be departing from the
plain and literal words of Section 17(2)(b) of the Act but such departure is sometimes necessary
(as it is in this case) to avoid absurdity. In the present case, since the cause of action arose at
Ambala, the State Consumer Redressal Commission, Haryana alone will have jurisdiction to
entertain the complaint.

KEHAR SINGH V STATE OF DELHI ADMINISTRATION

Interpretation must depend on the text and the context. They are the bases of interpretation.
One may well say if the text is the texture, context is what gives colour. Neither can be
ignored. Both are important. That interpretation is best which makes the textual
interpretation match the contextual. A statute is best interpreted when we know why it was
enacted.

AA HAJEE MUNIUDDIN V INDIAN RAILWAYS, AIR 1993 SC 361

The Railway Claims Tribunal Act, 1987 excludes the jurisdiction of all courts to
entertain claims against a railway administration and vests the same in the Claims
Tribunal constituted under the Act. The Act confers certain powers of civil courts
exercisable under the Code of Civil Procedure on the Tribunal but there is no specific
mention of the power under O 33 of the Code of Civil Procedure to entertain claims of
indigent persons. Still the Supreme Court ruled that the Tribunal must be held to have
the implied power of invoking the provisions of O 33 of the Code.

PYARALI K. TEJANI V. MAHADEO RAMCHANDRA DANGE.

• The appellant/petitioner, a dealer in scented supari, was charged with the offence of having
sold and retained for selling scented supari with saccharin and cyclamate, prohibited artificial
sweeteners, in contravention of S. 7(i)(ii) and rule 47 of the Prevention of Food Adulteration
Act, 1954 and thereby having committed an offence punishable under section 16(1)(a) (i) of
the Act.

• Court held that Supari is food within the meaning of S. 2(v) of the Act. The Act defines
'food' very widely as covering any article used as food and every component which enters
into it and even flavoring matter and condiments. In food offenses mischeif rule to be
applied. Appellant will be liable.

RANJIT D. UDESHI VS STATE OF MAHARASHTRA ON 19 AUGUST, 1964

Faced with such problems the courts although conscious of a dividing line, do not
attempt to draw it for reasons of practical impossibility and decide the particular case
in hand as falling within or outside the purview of the relevant words of the statute,
after laying down a working line or more appropriately some general working
principles.
On a question of construction of Indian statutes sobered use of foreign decisions of
countries following the same system of jurisprudence as ours and rendered on statutes
in pari materia has been permitted by practice in Indian Courts.

BENGAL IMMUNITY COMPANY V STATE OF BIHAR

In Bengal Immunity Company v. State of Bihar, the Supreme Court held that the marginal
notes to Article 286 of the Constitution was a part of the Constitution and therefore, it could be
relied on for the interpretation of that Article.

NOVAARTIS AG. V. UOI

In Novartis Ag. v. Union of India, the sectional headings were relied on while interpreting
Section 5, 3(d), 2(1) (j) and (ja) and 83 of the Patents Act, 1970.

Parliamentary Debates were also relied on by the Supreme Court while interpreting
provisions of the Patents Act, 1970. Section 2(1)(j) of the Patents Act, 1970, defines
"invention" to mean a new product or process involving an inventive step and capable
of industrial application and section 2(ja) defines "inventive step" to mean a feature of
an invention that involves technical advance as compared to the existing knowledge or
having economic significance or both and that makes the invention not obvious to a
person skilled in the art. By an amendment to the Act effective from 1 January 2005, it
was inter alia provided in section 3(d) of the Act that the mere discovery of a new form
of a known substance which does not result in the enhancement of the known efficacy
of that substance would not be an invention and also added an explanation to section
3(d). The Supreme Court referred to the Parliamentary Debates preceding the 2005
amendment and noted that the amendment to section 3(d) was the only provision cited
by the Government to allay the fears of the Opposition concerning the abuses to which
a product patent in medicines may be vulnerable. Hence, it was held that the
amendment to the provision was meant especially to deal with chemical substances,
and particularly pharmaceutical products and that, in addition to the standards laid
down in sections 2(1)(j) and (ja), the amended portion of section 3(d) clearly sets up a
second tier of qualifying standards for chemical substances/pharmaceutical products
in order to leave the door open for true and genuine inventions but, at the same time, to
check any attempt at repetitive patenting or extension of the patent term on spurious
grounds.

GUILD CORPORATION OF ORISSA LIMITED V EASTERN METALS AND

FERROY ALLOYS 2010

The golden rule of interpretation is that the words of a statute have to be read and understood
in their natural, ordinary and popular sense. Where however the words used are capable of
bearing two or more constructions, it is necessary to adopt purposive construction, to identify
the construction to be preferred, by posing the following questions:

(i) What is the purpose for which the provision is made?

(ii) (ii) What was the position before making the provision?
(iii) Whether any of the constructions proposed would lead to an absurd result
or would render any part of the provision redundant?
(iv) (iv) Which of the interpretations will advance the object of the provision?
The answers to these questions will enable the court to identify the
purposive interpretation to be preferred while excluding others.
LUCKNOW DEVELOPMENT AUTHORITY V MK GUPTA,AIR 1994

Section 2(1)(o) of the Consumer Protection Act, 1986 which is an inclusive

definition of "service" was held to include "housing construction" even before this
service was included expressly by amendment in 1993.

HARAYANA V BHARTI TELETAX LIMITED 2014 3 SCC

A statutory rule or an exemption notification which confers a benefit on the assessee

should be liberally construed, but the beneficiary should fall within the ambit of the rule
or notification. However, if there are conditions, and consequences of violation thereof
are provided, then the concept of liberal construction would not arise.

UOI V TATA CHEMICALS LTD AIR 2014 SC 3483

The principle that the words of a statute must be understood in their

natural, ordinary or popular sense, and construed according to their grammatical
meaning unless such construction leads to some absurdity or unless there is
something in the object of the statute to the contrary, was also applied by the court in
the interpretation of section 244A of the Income-tax Act, 1961, which is titled "Interest
on refunds"
USHA BRECO MAZDOOR SANGH VS MANAGEMENT OF M/S. USHA BRECO
LTD. ... ON 29 APRIL, 2008

The court was of the opinion that it must construe the statutory provision with a view to uphold
the object and purport of the Parliament. It is only in a case where there exists a grey area and
the court feels difficulty in interpreting or in construing and applying the statute, the doctrine
of beneficient construction can be taken recourse to. Even in cases where such a principle is
resorted to, the same would not mean that the statute should be interpreted in a manner which
would take it beyond the object and purport thereof.

SECRETARY, H.S.E.B VS SURESH & ORS ETC. ETC ON 30 MARCH, 1999

The court was of the opinion that the Contract Labour Regulation Act being a beneficial piece
of legislation as engrafted in the statute book, ought to receive the widest possible interpretation
in regard to the words used and unless words are taken to their maximum amplitude, it would
be a violent injustice to the framers of the law. As a matter of fact law is well settled by this
court and we need not dilate much by reason, therefor to the effect that the law courts exist for
the society and in the event of there being a question posed in the matter of interpretation of a
beneficial piece of legislation, question of interpreting the same with a narrow pedantic
approach would not be justified. On the contrary, the widest possible meaning and amplitude
ought to be offered to the expressions used as otherwise the entire legislation would loose its
efficacy and contract labour would be left on the mercy of the intermediary.