Explain the rule in 'Heydon's Case' while interpreting the Statutes quoting an example.
CA Intermediate · Corporate and Other Laws · MTP · September 2025
Explain the rule in 'Heydon's Case' while interpreting the Statutes quoting an example.
Suggested Answer and Working Notes:
Where the language used in a statute is capable of more than one interpretation, the most firmly established rule for construction is the principle laid down in the Heydon's case. This rule enables, consideration of four matters in constituting an Act: what was the law before making of the Act,what was the mischief or defect for which the law did not provide,what is the remedy that the Act has provided, andwhat is the reason for the remedy. The rule then directs that the courts must adopt that construction which 'shall suppress the mischief and advance the remedy'. Therefore, even in a case where the usual meaning of the language used falls short of the whole object of the legislature, a more extended meaning may be attributed to the words, provided they are fairly susceptible of it. If the object of any enactment is public safety, then its working must be interpreted widely to give effect to that object. Thus, in the case of Workmen's Compensation Act, 1923 the main object being provision of compensation to workmen, it was held that the Act ought to be so construed, as far as possible, so as to give effect to its primary provisions. However, it has been emphasized by the Supreme Court that the rule in Heydon's case is applicable only when the words used are ambiguous and are reasonably capable of more than one meaning [CIT v. Sodra Devi (1957) 32 ITR 615 (SC)].
Topics: Interpretation of Statutes
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