While drafting statutory definitions, the Legislature sometimes uses the word "means" and at other times the word "includes" and occasionally both…

Impact of "Means" and "Includes" in a Statutory Definition: 1. "Means" - When a definition uses the word "means", it is restrictive and exhaustive. The term is confined strictly to what is stated, and no other meaning can be given to it. Example: Section 2(34), Companies Act, 2013 "Director means a director appointed to the Board of a company". An exhaustive definition. 2. "Includes" - When a definition uses the word "includes", it is extensive in nature. The ordinary meaning of the word is retained and additionally enlarged to cover the categories specified. Example: Section 2(94) — "Whole-time director includes a director in the whole-time employment of the company" . It's an inclusive definition. 3. "Means and Includes" - Where both words are used together, the definition is treated as exhaustive. "Means" makes it a hard-and-fast definition, while "includes" merely brings in specified matters that would not otherwise fall within its ordinary meaning; nothing beyond the stated enumeration is covered. Example: "Associate company", in relation to another company, means a company in which that other company has a significant influence, but which is not a subsidiary company of the company having such influence, and includes a joint venture company. This is the classic example of use of "means and includes" . The "means" clause sets the boundary, and the "includes" clause deliberately stretches that boundary to capture additional, specified categories.