|| Shree ||

PPT 1: INTERPREATATION OF STATUTES

NOTES

LITERAL RULE OF CONSTRUCTION

• The literal rule means the words of statute are understood in their natural, ordinary,
and popular sense. Phrases and sentences are to be construted in their grammatical
meaning unless it leads to any absurdity.

Jugalkishore Saraf v. Raw Cotton Co. Ltd.: (Justice S.R. Das) called it the Cardinal Rule of
Construction

§ If words are clear, follow them.

§ If absurd, only then modify meaning.

Kanai Lal Sur v. Paramnidhi (1957): (J Gajendragadkar) –

§ Words must be given plain grammatical meaning.

§ Only if 2 meanings possible, then object of law (act or policy) is to be considered.

Correcting Over-Liberal or Over-Strict Constructions

Raghunath Rai Bareja v. PNB (2007)

• Sometimes courts go too wide (liberal) or too narrow (strict).

• Supreme Court in this case warned against such tendencies.
• Judicial restraint is needed – courts should not expand or restrict law unnecessarily.

Limits of the Literal Rule

• Literal rule emphasizes natural, ordinary, grammatical, and popular sense.

• But words cannot be read in isolation – must be read in context.
• “No word has absolute meaning without context.”
• Departure allowed only when:
1. Literal meaning = absurd
 2. Inconsistent with law’s purpose
3. Makes law unworkable

Word “bank” means financial institution, but in “river bank,” it means land by river.

APPLICATION OF LITERAL RULE

Language Read As It Is

1. Statute must be read as a whole:

o No section should be isolated.
o Each part must fit into overall scheme. (every section must be construed
conjointly)
2. Context-sensitive interpretation:
o Words may change meaning depending on context. So, while the rule mandated
plain reading, it is not blind literalism.
3. Avoid adding or subtracting words:

• Courts cannot add or subtract words in a statute.

• Privy Council: Judges cannot fill gaps left by legislature.

British India General Insurance v. Itbar Singh (1959):

o Even a seemingly harmless addition was rejected by the court.

o SC stated that rejection or addition of words is allowed only in ‘exceptional
circumstances’- not to re-draft legislation, but solely “to achieve the purpose of
the Act or to give a purposeful meaning

Exception to Literal Rule:

• Permissible supply of words by implication: Courts may supply missing words by

implication, if text becomes meaningless, or entirely ineffective.
• Permissible rejection of surplus words: Courts may ignore extra words if they nullify
law’s purpose. Only to prevent a clear legislative object from being nullified.
 • Treating Words or Provisions as Superfluous: Sometimes a statute has redundant or
repetitive words (due to poor drafting).

- General principle: every word has a purpose.

- But courts can treat some words as superfluous if:

1. They are clearly unnecessary.

2. Their inclusion confuses the law.
3. The rest of the Act shows they were inserted by mistake.

MISCHIEF RULE OF INTERPRETATION

Mischief Rule allows to interpret laws in a manner that addresses the “Mischief” or “Defect”
the legislation aims to resolve.

• Focus: identify the mischief or defect the law intended to cure.

• Origin: Heydon’s Case (1584).
• Objective: suppress the mischief and advance the remedy. (The basic object of this rule
is to remove doubt regarding the meaning of legal words and to detect the 'abuse' or
evil that the legislature wishes to correct)
• Courts look at intention of legislature, not just words.

Four Step Test (Heydon’s Case) that courts should consider:

1. What was the law before the statute?

2. What defect or mischief that the previous law did not address?
3. What remedy did the parliament provided via statute?
4. What was the reason behind the remedy?

Example: Before Rent Control Acts, tenants could be easily evicted. The “mischief” was
arbitrary eviction, and the “remedy” was protection of tenants.
Application of Mischief Rule –

• Bengal Immunity Co. v. State of Bihar (1955):

o Article 286(1)(a) prevented states from taxing inter-state sales.
o Mischief = multiple taxation barriers between states.
o Court applied mischief rule to promote free trade.
• K.P. Varghese v. ITO (1981):
o Sec 52(2) Income Tax Act could tax genuine sales if read literally.
o Court restricted its use only to tax evasion cases.

• Workmen of Dimakuchi Tea Estate v. Management (1958):

o Defined “industrial dispute.”
o Court said dispute must be real and substantial, involving those directly
affected.
• Smith v. Hughes (1960):
o The Street Offences Act 1959 prohibited prostitutes from ‘loitering or soliciting
in the street’.
o The issue here was that Prostitutes were contenting that they were soliciting
from windows and balconies, arguing they weren't ‘in the street’.
o Court: purpose was to stop public solicitation and harassment, so windows and
balconies were deemed extensions of street.

Limitations of Mischief Rule (1)

• Cannot contradict or override clear statutory language.

• Cannot Insert meanings unsupported by the text.
• Cannot be used to Interpret a provision where no ambiguity exists.

1. Umed Singh v. Raj Singh (1975)

- Courts must not ignore plain natural meaning.
2. Kanailal Sur v. Paramnidhi (1957)
- Mischief rule applies only when words are ambiguous.

3. CIT, MP v. Sodra Devi (1957):

 - Rule applies only when words in question are ambiguous and are reasonably capable
of more than one meaning.
- Courts may use extrinsic aids (Law Commission reports, debates, historical
background).

PURPOSIVE RULE OF INTERPRETATION

The Rule states that, statutes must be read “in light of their purpose,” and ambiguous or general
words are interpreted to further regulatory, social, or economic objectives rather than adhering
strictly to their dictionary meaning.

• The purposive rule is an evolution and expansion of the mischief rule.

• Mischief rule = cures specific defect.
• Purposive rule = looks at the overall purpose/objectives of legislation.
• Common in EU & common law (teleological interpretation).
• Lord Diplock (Carter v. Bradbeer): Courts courts should ascertain the purpose or object
of the enactment from the Act as a whole and interpret ambiguous phrases in the
manner that best advances that purpose.

Purposive Rule – Comparison with Mischief Rule

• Both prevent mechanical literalism.

• Mischief Rule: narrow – only cures specific gap.
• Purposive Rule: broader (considers text, context, extrinsic materials, and object of
statute)

Purposive Rule – How Courts Apply It

Courts can consider:

1. Legislative objectives (stated or implied).

2. Social, political, historical context.
3. Reports, committee findings, objects, and reasons.
4. Modern needs and realities.

It is frequently used in constitutional interpretation, social welfare statutes.

Application of Purposive Rule – Cases

• K. Prabhakaran v. P. Jayarajan (2005):

- Purposive approach used to construe disqualification under electoral law

- aim to bar criminal elements from legislatures.

• Royal College of Nursing v. DHSS (1981, UK):

- The court rejected strict literalism and adopted Purposive approach which allowed
nurses to undertake procedures under the Abortion Act, in line with the statutory aim
of safe abortions, despite literal wording.
- Section 1(1) of the Abortion Act 1967, which stated: “a person shall not be guilty of
an offence under the law relating to abortion when a pregnancy is terminated by a
registered medical practitioner”
- Involvement of nurses would be unlawful as per the literal reading.
- Only Doctors must carry out the procedure.
- By 1981, medical practice had evolved significantly.
- Surgical abortions > replaced with medical induction procedures(Prostaglandin drug)>
routinely administered by nurses not doctors

RULE OF HARMONIOUS CONSTRUCTION

• Aim: Resolve conflicts within a statute or between statutes.

• No provision should render another meaningless. (avoid contradiction, promote
consistency)
• Law must be read as an integrated whole. (reading of Statute as an integrated entity)
• Courts balance competing provisions to uphold legislative intent.

5 key principles governing this rule (CIT v. Hindustan Bulk Carriers)

1. Avoid direct conflicts, by harmonizing contradictory provisions.

2. No provision defeats another unless reconciliation impossible.
3. If full reconciliation not possible, give both maximum effect.
4. No provision should become a dead letter. (such interpretation is not permissible)
5. Harmonization should not destroy or render any statute’s essence.

Application of Harmonious Rule

 • Applied in:
1. Internal inconsistencies within a single statute.
2. Conflicts between two statutes.
3. Ambiguities in constitutional provisions.
• Often used to balance competing interests like environment vs. development.
• In Constitution, ensures Fundamental Rights & Directive Principles coexist.

Summary: Harmonious construction prevents clashes and promotes balance.

Application – Harmonious Construction (Cases)

• Venkataramana Devaru v. State of Mysore (1958):

o Conflict: Art. 25(2)(b) (temple entry for all Hindus) vs. Art. 26(b)
(denominational rights).
o Court harmonized → temple entry allowed, but denominational practices
(essential religious practices) preserved.
• J.K. Cotton Spinning & Weaving Mills v. State of U.P. (1961):
o Two conflicting clauses in a labor notification.
o Court read the broader one in line with the narrower one → avoided redundancy.

• Kesavananda Bharati v. State of Kerala (1973):

o Conflict: Parliament’s power to amend Constitution (Art. 368) vs. basic
structure of Constitution.
o Court: Parliament can amend, but not alter basic structure of consti.
• Minerva Mills v. Union of India (1980):
o Conflict: Art. 31C (Directive Principles > Fundamental Rights) vs. basic
structure.
o Court struck down part of Art. 31C → balance between social justice &
individual rights.

Exception – Harmonious Construction

• Rule does not apply if:

1. Reconciliation impossible (two provisions irreconcilably conflict).
2. Legislature expressly overrides one provision (e.g., non obstante clause).
 3. Court would have to introduce meanings beyond intent.

Summary: Harmonization works only if reconciliation is possible and intent is respected.

RULE OF REASONABLE CONSTRUCTION

• Latin maxim: Ut Res Magis Valeat Quam Pereat = that the thing may rather have
effect than be destroyed.
• Courts interpret statutes to be effective, not void.
• Aim: adopt common sense interpretations that uphold validity.
• Bridges literal meaning with practical reasonableness. (GOLDEN RULE)
• When a provision’s language is inexact but its intent is clear, courts adopt a reasonable
construction to effectuate law.

Case: RBI v. Peerless general finance and inverstment: (J. O chinnappa reddy)

- Statutory provisions – must be construed – with the object / purpose of legislation

- Language – interpreted in context – not is isolation (out of context)
- Words – to be understood in harmony with entire statute

Exception – Reasonable Construction

• Rule cannot save a law if:

1. No reasonable construction possible.
§ Indira Sawhney v. Union of India (1992): certain state laws exceeded
competence, struck down.
2. Rule does not allow rewriting statutes.
3. Cannot override explicit directives, even if absurd.

Summary: Reasonable rule works only if interpretation can actually save law within limits.

RULE OF EJUSDEM GENERIS

- Of the same kind of species
- The general word takes its meaning from previous expressions. (therefore, restricts
scope of general words)
• Cases: siddeshwari cotton mills v. UOI: SC interpreted “any other processes” following
species like.. bleaching, dyeing, printing.
• Application: Amar Chandra Chakraborty v. Collector of exise (essentials to apply this
rule given)
- Statute must contain list of specific words
- Listed items must form a class
- Class formed is not exhausted
- A general terms follows a list
- There is a broader category that includes multiple types
- No contarary legislative intent should appear.
• Exception:
- It does not apply to words which lack genus.
- If enumeration exhausts the category
- If legislative intent indicates a broader meaning
- Inapplicable to clear, unambiguous language, or where it defeats statute’s intent
 PPT 2: BASIC RULES OF INTERPRETATION

Interpretation – Meaning and Concept

• Laws are drafted by experts but still not precise → scope of interpretation always exists.
• Lord Denning (Seaford Court Estates Ltd. v. Asher): Laws cannot be as precise as
mathematics. Judges must step in to correct defects.
• Case: Keshav Mills & Co. Ltd. v. CIT (1965): When two reasonable interpretations
exist, judges face a delicate task.

Importance of Interpretation

• Interpretation needed because:

o Statute making ≠ Interpretation. Legislature makes law, courts interpret.
o Object = determine legislature’s intent (expressed or implied).
o Courts cannot interpret arbitrarily

Need for Interpretation

• If statute words are clear → no interpretation needed.

• If multiple meanings possible → interpretation is essential.
• Example: Section 3, Companies Act:
o “A company may be formed for any lawful purpose.”
o Word “may” → does it mean optional (directory) or mandatory (compulsory)?
o Two possible interpretations:
1. Company can be formed for lawful purpose.
2. Company cannot be formed for unlawful purpose.

• Courts interpret based on legislative intent.

• “May” sometimes = “shall” depending on context.
• Case: State of U.P. v. Manbodhan Lal Srivastava (1957): “May” can be mandatory
if context demands. It’s not always discretionary.

Provisions Requiring Interpretation (Part 1)

 • Ambiguous words needing interpretation: “may,” “shall,” “reasonable,” “satisfaction,”
etc.
• Examples:
1. Sec 11, RTI Act: PIO may disclose info of third party → discretionary?
2. Sec 125, CrPC: Maintenance → depends case to case.
3. Sec 20, Hindu Adoptions & Maintenance Act: Parent must maintain children
“unable to maintain themselves” → requires interpretation.
4. Sec 14, Hindu Marriage Act: Divorce only after 1 year unless hardship →
court’s satisfaction needed.

• Case: Kedar Nath Singh v. State of Bihar (1962):

o Court upheld sedition law but restricted meaning.
o Only speech causing violence or public disorder = sedition.
o However, to safeguard Article 19(1)(a), it had to be read
down in a narrow, restricted sense.
o Criticism of government ≠ sedition.

Necessity of Interpretation

• Interpretation needed only if provision is ambiguous.

• Case: R.S. Nayak v. A.R. Antulay (1984):
o Words must be given natural meaning unless absurd.
o Courts start with literal meaning → deviate only if absurd.
• This is Literal Rule.

Object/Function of Interpretation

• What? → Find meaning / comprehend - legislative language.

• Why? → To know intention/purpose/spirit of law.
• Keeton’s View: Judge’s function = interpret law’s words & object.
Difference – Interpretation vs Construction

• Interpretation: linguistic meaning

o Finding true sense of statute.
o Deals with linguistic meaning.
o Used when text is clear.
• Construction: legal effect
o Drawing inferences beyond text.
o Deals with legal effect.
o Used when text ambiguous.
• Case: U.S. v. F.W. Keitel: in common usage these two words have same significance

Statutes & Types

• Statute = Formal written enactment by legislature.

• Will of legislature in the form of text (Maxwell).

BASIC RULE OF INTERPRETATION

1. Intention of the legislature:
• Latin maxim: Animus Imponentis = “the intention of the imposer (law-maker).”
• If statutory words allow more than one meaning, courts must choose the interpretation
that best reflects legislative intent.
• Case: RMD Chamarbaughwala v. Union of India (1957) → “A statute is to be
construed according to the intent of those who make it.”
• Words are not precise symbols; they can have different meanings depending on context
and time. Courts must select the meaning that best fits the law’s purpose.

Challenges in Finding Intention

• Courts often face borderline confusion where exact meaning is uncertain.

• Example: Word “Building”
 o Does it mean only the superstructure, or also land, or even open platforms?
o Cases:
§ State of Bombay v. Venkat Rao (1966): Open platform with no walls/roof →
not a building.
§ Int’l Airport Authority Employees Union v. IAAI (2001): Parking areas at
airports = building.
§ CIT v. Gwalior Rayon (1992): Roads & drains inside a factory treated as
building for tax.
§ Ashok Kapil v. Sona Ullah (1996): Roofless structure also a building.
o These show how courts stretch meaning to fulfil legislative intent.

Balancing Certainty vs. Flexibility

• Legislature writes laws for present and future.

• Laws often use broad/general words → ensures flexibility.
• But this creates uncertainty → Courts must interpret carefully.
• Case: State of Bombay v. Hospital Mazdoor Sabha (1960): Court said sometimes
it’s practically impossible to strictly mark boundaries; hence, general principles must
guide interpretation.

Role of Courts

• Courts must expound the law, not create new law.

• But in practice, they sometimes mould or creatively interpret laws → acting as
“finishers, refiners & polishers.”
• Case: Bangalore Water Supply v. A. Rajappa (1978): Court expanded “industry”
definition to include many activities not originally covered—example of filling gaps.
• But judicial law-making should be minimum. Judges should not rewrite laws just
because they disagree.
• Principle: Statute is master, judgment is servant.

Combined Approach: Meaning + Purpose

• Courts must give effect to both:

1. Literal meaning (what words say).
 2. Purpose & object (why law was enacted).

Judicial Opinions on Intention

• Union of India v. Elphinstone Spinning (2001):

Intention of legislature is the cardinal principle of construction. Courts must balance
subjective (individual rights) & objective (public purpose) aims.
• Kanailal Sur v. Paramnidhi Sadhukhan (1957): (J. Gajendragadkar)
First and primary rule → find intention of legislature from words used.
• Utkal Contractors v. State of Orissa (1987):
In case of doubt, courts should always keep an eye on the object, purpose, or spirit of
the law.

STATUTE MUST BE READ AS A WHOLE

• Latin maxim: Ex Visceribus Actus → “from the entrails of the Act.”

• Principle: You cannot interpret a section in isolation. Every provision must be read in
the context of the entire statute to capture legislative intent.
• Maxwell on Interpretation:
o “No part of a statute can be read in isolation: the meaning of each section
depends upon its relation to the whole.”
o Even definitions may change their meaning depending on the statutory setting.

• State of West Bengal v. Union of India (Justice Sinha):

Court must ascertain intention not just from one clause but by looking at the entire
statute and the setting in which the clause occurs.
• Union of India v. Elphinstone Spinning & Weaving Co. Ltd.,
To understand context, court should consider:
1. The statute as a whole,
2. Previous law,
3. Other statutes in pari materia (on same subject),
4. The general scope of the Act,
5. The mischief intended to be remedied,
6. The historical context of enactment.
Components Courts Consider (“Read as Whole” Approach)

To interpret correctly, courts look at:

1. Long Title & Preamble → reveal purpose.

2. Definitions → must be applied uniformly
3. Operative Provisions → interpreted in light of each other.
4. Schedules/Annexures → must align with the main Act.
5. Subsequent Amendments → checked to ensure consistency with original purpose.

STATUTE TO BE CONSTRUED TO MAKE IT WORKABLE:

• Latin Maxim: Ut Res Magis Valeat Quam Pereat

→ “It is better for a thing to have effect than to be made void.”
• Courts must interpret provisions in a way that allows the law to function effectively.

• A statute must be construed to make it operative and meaningful.

• If there are two possible interpretations:
o One makes the law self-defeating,
o Another preserves its purpose,
→ Courts will adopt the workable interpretation.

• Avoidance of Futility- If one reading makes the provision self-defeating, and another
makes it consistent with legislative intent, the latter must be adopted.
• Harmonization- Must reconcile all sections to work together, so no clause is
redundant.
• Contextual Flexibility–Especially in social or economic legislation, a broader,
purposive construction is favoured to further public welfare

• Workmen of Dimakuchi Tea Estate v. Management of Dimakuchi Tea Estate,

o Industrial Disputes Act used the phrase “any person.”
 o If read literally, it could include any random individual, making the Act
unworkable.
o Court restricted meaning → “any person” means only those connected with
workmen.
o This preserved the law’s effectiveness.

• Courts must prefer interpretations that keep statutes alive, functional, and effective.
• Even if literal meaning is possible, if it defeats the law’s purpose, courts lean towards
a purposive, workable construction.

PRINCIPLE OF PLAIN MEANING

- Words must be understood in their natural, ordinary, or popular sense unless they have a
technical meaning. The object of interpretation is to ascertain the intent of the legislature.
But if the words themselves are clear and unambiguous, they best declare such intent.
- Case: Kanailal Sur v. Paramnidhi Sadhu Khan: plain grammatical meaning of the words
must be adhered (unless it leads to absurdity).

PRESUMPTIONS OF THE STATUTES

PPT 3

SUBSIDARY RULES OF INTERPRETATION

Subsidiary rules are secondary guiding principles courts use when primary interpretation
rules (like literal, golden, mischief rule) don’t give a clear answer.
They are judicially evolved presumptions which refine statutory interpretation.
EXCEPTIONS: Context, legislative intent, specific statutory language.

Same Words to Have Same Meaning

• Bhogilal Chunnilal Pandya v. State of Bombay: If the legislature uses the same
word in different sections of the same law, the presumption is that the word carries
the same meaning everywhere, unless the context demands otherwise.

Same Words To have same meaning.

• Weakened presumption: The same word may be read differently in different

sections if the context and purpose justify it.
• Shamrao Vishnu Parulekar v. DM, Thana (1957): Phrase “grounds on which the order
has been made” in Preventive Detention Act had different meanings in Section 3(3)
and Section 7 due to the procedural context.

Use of Different Words = Presumption of Different Meanings

If lawmakers use different words in the same statute, they are presumed to intend different
meanings, not synonyms.

• Arthur Paul Benthall (1956): “Distinct matters” vs. “two or more descriptions” under
Stamp Act presumed to be different.
• BMC v. Willingdon Sports Club (2013): Distinguished between profit and gain →
“gain” includes advantage, not limited to money profit.
• Econ Antri Ltd. v. Rom Industries Ltd (2014): Words like “of”, “from”, “after” may
carry identical meanings despite differences.

Rule of Last Antecedent

In grammar and law, qualifying words usually apply to the word/phrase immediately
before them, not the whole sentence.

Cases:
RULE OF NON-OBSTANTE CLAUSE

A clause beginning with “Notwithstanding anything contained…” overrides conflicting

provisions. It ensures priority to the section where it appears.

• Central Bank v. State of Kerala (2009): Non obstante is applied only where there is
actual inconsistency.

Conflict Between Two Non-Obstante Clauses

If two laws both start with "notwithstanding..." how to resolve?

Principles:

1. Temporal precedence – newer law prevails (later enactments generally prevails)

AP State Financial Corp. v. Official Liquidator, 1992 - When two statutes contain conflicting
non-obstante clauses, the later statute generally prevails unless there are compelling reasons
to hold otherwise.

2. Specificity principle – particular law overrides general one.

3. Harmonious construction – if Acts cover different fields, both can coexist (BALCO
v. Kaiser, 2018).

Conjunctive & Disjunctive Words

• And / Or interpretation:
o ‘And’ → All conditions must be met.
o ‘Or’ → Any one condition satisfies.
• Courts may substitute “and ↔ or” to avoid absurd results or serve intent.
• Examples:
o R.S. Nayak v. A.R. Antulay: “And” was read as “or” to prevent corruption law
deadlocks. (disjunctive reading)
 o Prof. Yashpal v. State of Chhattisgarh (2005): “Established or incorporated”
read conjunctively to protect university quality. (conjunctive reading)
o Sanjay Dutt case: arms and ammunition – ‘and’ construed disjunctively.

Rule of Legal Fiction

When legislature “assumes something to be true which is not so, and directs that it be treated
as true for the purpose of the statute.”

• Limitations (Cases):
o East End Dwellings v. Finsbury (1952/India adoption in CIT v. S Teja Singh):
Fiction must be carried to its logical conclusion but not be extended beyond its
legitimate field or the language of creating section.
o Bengal Immunity Co. v. Bihar (1955): {J. S.R. Das} said… “Only for some
definite statutory purpose, should not be extended beyond that legitimate
field”

Mandatory & Directory Provisions

• Mandatory: it has to be strictly complied with. (Non-compliance = invalid)

• Directory: Procedural guidance, flexible; non-compliance does not automatically
invalidate.
• Tests (from Manbodhan Lal Srivastava, 1957): stated that, question whether
provision is mandatory or directory depends upon the intent of the legislature and not
upon the language.
1. It is not based on merely the language
2. Statute’s object and scheme
3. Nature and design of the provision
4. Consequences of non-compliance
 • Application:

Mandatory provision: when legislature wants to create essential condition that

validated the act. If it intends to protect substantial rights. (usually mandatory.. no
person shall, nothing shall be valid unless, etc)

Directory provision: if it is a guideline that outlines a procedure/formality, not

supposed to nullify actions. If it relates to procedure, do not have any penalty in case
of failure.

• Cases:
o Babu Verghese (1999): Negative language + statutory consequence →
mandatory.
o Topline Shoes v. Corporation Bank (2002): Deadlines were directory unless
any prejudice caused.
o Lalita Kumari (2014): FIR registration mandatory (to protect citizen’s right)
due to fundamental rights.

Three step process to check:

1. Examine the wording: look for imperative/prohibitive expressions

2. Analyse legislative purpose: identify whether provision protects substantive
rights or ensures procedural orderlinesss
3. Assess consequences: determine if nullifying non-conpliance would further
the statute’s objective or defeat it.

RULE OF GENERAL WORDS

• General words like “any, all, every” are meant to be broad, covering all possible
cases. They cannot be read in isolation.
• They are accompanied by Ejusdem Generis and Nocitur a sociis
• Cases: VD Jhingan v. State of UP (1966): “Any connection whatever” → very broad
meaning upheld.
 • Case: Empress mills Nagpur v. Municipal committee Wardha: general words must be
limited to the actual object of the act.
• Case: Kedar Nath Singh v. State of Bihar: “Disaffection towards government” in
124A IPC – restricted its scope to acts inciting violence.

• Controlled by:
o Context & purpose.
o Constitutional principles.
o Ejusdem generis / noscitur rules.

NOSCITUR A SOCIIS

• Word’s meaning known from the company it keeps. (it is associated by its associates)
• Courts use this maxim to interpret ambiguous terms by considering their context in
the statutory language, preventing isolated or overly broad meanings.
• Cases: (application)
o Rohit Pulp Mills v. Collector: Tariff items classified by context of neighbors.
o Alamgir v. State of Bihar: “Detain” interpreted in line with “entice, conceal”
→ only coercive detention. (section 498 ipc)
• Cases: (exception)
o State of Bombay v. Hospital Mazdoor Sabha: Cannot cut down clear
legislative intent – useful only when ambiguity exists.

REDDENDO SINGULA SINGULIS

• Meaning: “Render (Distribute) each to each” → when multiple subjects & predicates
exist, assign them logically. (avoid illogical paring)
• Applicable where there are various antecedents and consequences.
• Example: “Draw or load any sword or gun” → draw applies to sword, load applies to
gun.