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Interpretation of Statutes

The doctrine of Beneficial Construction

The term ‘Interpretation’ is derived from the Latin term ‘interpretari’ which means to explain or to understand or translate. Interpretation is a process through which one ascertains the true and correct intention of the law-making bodies as is laid in the form of statutes. It is a familiar feature of law and legal practices. Interpretation is an important aspect of the practice of law. The interpretation has a very important role in justice administration in the sense that it helps the legal system “understand” the law. Interpretation makes understanding possible of the subject. Interpretation is the art of finding out the true sense of any form or words; i.e. the sense which their framers intended to convey, and of enabling others to drive from them the same idea which the author intended to convey. Interpretation only takes place if the text conveys some meaning or other. Thus the courts are expected not to act arbitrarily and consequently, they are to follow the rules of interpretation. For interpretation of the statute, the court has to apply some principles and rules, the rule of beneficial construction is one of them.

Golden Rule of interpretation is that the grammatical ordinary sense of the words is to be adhered unless that would lead to absurdity or inconsistency. Where the words In question are ambiguous and are reasonably capable of more than one meaning, courts must adopt the construction which may suppress the mischief and advance the remedy.

Beneficial Construction

Beneficial construction involves giving the widest meaning possible to the statutes. When there are two or more possible ways of interpreting a section or a word, the meaning which gives relief and protects the benefits which are purported to be given by the legislation should be chosen.

A beneficial statute is a class of statute which seeks to confer a benefit on individuals or class of persons by relieving them of an onerous obligation under contracts entered into by them or which tend to protect persons against oppressive act from individuals with whom they stand in certain relations. Laws which are enacted with the object of promoting the general welfare and facing urgent social demands receive beneficial legislation. Examples of statutes include The Factories Act, Industrial Disputes Act, etc. A beneficial statute has to be construed in its correct perspective so as to fructify the legislative intent. Although beneficial legislation does receive liberal interpretation, the courts try to remain within the scheme and not extend the benefit to those not covered by the scheme. There is no set principle of construction that beneficial legislation should always be retrospectively operated although such legislation is either expressly or by necessary intendment not made retrospective.

In Budhan v. Nabi Bux AIR 1970 S.C. 1980 case, the Court observed that the object of every legislation is to advance public welfare. Justice and reason constituted the great general legislative Intent In every piece of legislation.

In Tola Ram v. the State of Bombay, AIR 1954 S.C. 496 case, the Court observed: “It is a well-settled rule of construction of penal statutes that if two possible and reasonable constructions can be put upon a penal provision, the Court must lean towards that construction which exempts the subject from penalty rather than the one which imposes a penalty.”

In Commissioner of Income Tax Punjab v K.V. Trans Co. (P) Ltd., 1970 (2) S.C.C. 192 case, the Court said: “It is said that in a Taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used. However, while construing the provisions of a taxing statute, if two views are possible the view which is favourable to the assessee must be accepted.”

In Munni Devi v. Hem Prakash, 1981 All. Civil Journal (25) case, the Court observed that the rules of procedure are said to be the handmaid of justice. It is settled law, that procedural provisions should not be used as traps to catch litigants unaware, they should be construed so as to advance the cause of justice.

In B Shah v Presiding Officer, AIR 1978 SC 12 case,  Labour Court applied the rule of beneficial construction in construing section 5 of the Maternity Benefit Act, 1961, which makes the employer liable to pay maternity benefit to a woman worker at the rate of average daily wage for the period of her actual absence immediately preceding and including the day of her delivery and for six weeks immediately following that day. The court held that Sundays must also be included and held that the Act was intended not only to subsist but also make up for her dissipated energy and take care of the child. The Act was read in the light of Article 42.

In Sheela Barse v. Union of India, AIR 1986 SC 1773 case, a petition was filed by a social worker seeking the release of children below 16 years who were detained in jails. It was observed by the Supreme Court that clause (f) of Article 39 provides that children are given opportunities and facilities to develop in a healthy manner and in conditions of freedom and dignity and that childhood and youth are protected against exploitation and against moral and material abandonment. Although Acts are on the statute book, in some states the Acts have not brought into force. The Supreme Court held that this piece of legislation is for the fulfillment of a constitutional obligation and a beneficial statute. Ordinarily, it is a matter for the State Government to decide as to when a particular statute should be brought into force but in the present setting we think that it is appropriate that without delay every state should ensure that the Act is brought into force and administered in accordance with its provisions.

Conclusion:

Laws which are enacted with the object of promoting the general welfare and facing urgent social demands receive beneficial legislation. A beneficial statute has to be construed in its correct perspective so as to fructify the legislative intent. Although beneficial legislation does receive liberal interpretation, the courts try to remain within the scheme and not extend the benefit to those not covered by the scheme.

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