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Interpretation of Statutes: Understanding the Will of Legislature

Interpretation is the primary function of a court. The court interprets the legislature4 whenever a dispute comes before it. Since the will of the legislature is expressed generally in the form of statute, the prime concern of the court is to find out the intention of the legislature in the statute.[1]

Statutes, or the written laws passed by legislatures, are the foundation of any legal system. However, their language can be complex and ambiguous, necessitating interpretation to ensure fair and consistent application of the law. This article explores the process of statutory interpretation, a fundamental aspect of the legal system, to uncover the true intent of the legislature. While statutes govern various aspects of society, their interpretation is not always straightforward. This article delves into the methods and principles used to interpret statutes, ultimately aiming to clarify the will of the legislature.

Historical Background
The concept of statutory interpretation has a long and rich history, tracing its origins to ancient legal systems where scribes and scholars grappled with the meaning of legal texts. Early common law judges relied heavily on the "mischief rule," established in Heydon's Case (1584), which focused on the problem a statute aimed to address. Over time, as legal systems evolved, so did the methods of interpretation, transitioning from the early days of strict literalism to the modern era of purposive interpretation. This journey of statutory interpretation reflects the evolution of legal thought and principles, incorporating various principles and aids to arrive at the most accurate interpretation.

Source Of Law
In understanding statutes, it is essential to recognize the various sources of law that inform interpretation. Legal systems rely on a foundation of established sources that dictate what constitutes the law. These include not only the text of the statute itself but also legislative history, judicial precedents (past court decisions), legal principles, customary law and societal norms. Each of these sources contributes to the comprehensive understanding of legislative intent and aids in resolving ambiguities in statutory language. Here's a quick breakdown of the main sources:
  • Legislation:
    • Laws passed by a legislative body, often a parliament or congress. These are formal written enactments that establish rules and regulations.
  • Judicial Precedent:
    • Court decisions in prior cases that set legal principles. Lower courts often follow the rulings of higher courts in similar cases, creating a body of case law.
  • Constitution:
    • The supreme law of a country, outlining the framework of government, fundamental rights, and core principles.
  • Customary Law:
    • Unwritten rules derived from longstanding traditions and practices, often recognized by courts in the absence of formal legislation.
  • Treaties and International Law:
    • Agreements between nations that can influence domestic law and hold legal weight within a country's legal system.

Meaning Of Statutes
The primary objective of statutory interpretation is to determine the intended meaning of the legislature when enacting a statute. This meaning isn't always readily apparent and may require deeper analysis of the statutory language and context. While statutes encompass a wide range of legal instruments and are drafted with precision, the complexities of language and evolving societal contexts often necessitate interpretation. This process involves decoding the meaning of the words and phrases used within the statute to determine their intended legal effect. A statute is the will of the legislature. It may have the following particulars:
  • Short Title
  • Long Title
  • Preamble
  • Marginal Notes
  • Headings of a group of sections or of individual sections
  • Provisos
  • Illustrations
  • Exceptions and Saving Clauses
  • Explanations
  • Schedules
  • Punctuation

Objects Of Interpretation Of Statutes

The interpretation of statutes holds paramount importance in legal systems for several reasons
  • Clarifying Legislative Intent:
  • Statutes, drafted by legislative bodies to regulate society, can be complex and open to interpretation. Interpreting statutes clarifies legislative intent, ensuring consistent and fair application of laws.
  • Preserving the Rule of Law:
  • Effective statutory interpretation upholds the rule of law by providing clear guidance on how laws should be understood and applied, promoting legal certainty and public trust in the legal system.
  • Resolving Ambiguities and Conflicts:
  • Interpretation helps resolve ambiguities and conflicts in statutory language, ensuring consistent application of the law in line with legislative intent and preventing confusion and instability in the legal system.
  • Adapting to Societal Changes:
  • Interpretation allows laws to adapt to evolving societal norms and values, ensuring their relevance and effectiveness in addressing contemporary issues and concerns.
  • Balancing Rights and Responsibilities:
  • Statutory interpretation involves balancing competing rights and interests to serve both individual freedoms and societal welfare, ensuring laws are applied in a manner that respects fundamental rights.
  • Promoting Access to Justice:
  • Clear interpretation of statutes ensures all individuals can understand their rights and obligations under the law, empowering them to seek redress through the legal system and promoting fairness in the administration of justice.
Classification Of Statutes
Statutes can be classified in various ways, including public and private, criminal and civil, substantive and procedural. Each classification may require distinct methods of interpretation tailored to its specific context and purpose. Understanding the nature of the statute being interpreted is crucial for applying the appropriate interpretive framework.

Classification by Duration:

  • Temporary Statute
  • Permanent Statute

Classification by Method:

  • Mandatory or Imperative Statute
  • Directory or Permissive Statute

Classification by Object:

  • Codifying Statute
  • Consolidating Statute
  • Remedial Statute
  • Enabling and Disabling Statute
  • Penal Statute
  • Taxing Statute
  • Amending Statute
  • Repealing Statute

Classification by Application:

  • Public Statutes
  • Private Statutes

Classification by Nature of Law:

  • Civil Statutes
  • Criminal Statutes

Classification by Area of Operation:

  • General Statutes
  • Local Statutes

General AIDS To The Interpretation Of Statutes

General aids of interpretation are tools and principles used by courts and legal practitioners to understand the meaning and intention behind statutes. These aids help navigate through the complexities of statutory language and ensure consistent and accurate application of the law. Here are some key general aids of interpretation

Internal AIDS

Internal aids to the interpretation of statutes are tools or resources found within the statute itself that assist in understanding its meaning and application. Internal aids to interpretation refer to clues found within the statute itself, such as definitions, headings, and punctuation, which assist in ascertaining legislative intent. These internal aids are inherent to the statutory text and include various components that provide context or guidance for interpretation. Here are some common internal aids to the interpretation of statutes:
  • Text of the Statute:
    The primary source of law for interpreting statutes is the text of the statute itself. Courts examine the language used in the statute, including the words and phrases employed, to ascertain the meaning intended by the legislature.
  • Preamble:
    The preamble of a statute often provides valuable insight into the purpose and objectives of the legislation. It may outline the reasons for enacting the statute and the intended scope of its application. Courts may refer to the preamble to understand the legislative intent and interpret ambiguous provisions in light of the preamble's objectives.
  • Title and Heading:
    The title and heading of a statute can offer clues about its subject matter and scope. While they are not determinative of legislative intent, they can provide context and assist in understanding the overall structure and purpose of the statute.
  • Definitions Section:
    Many statutes include a definitions section clarifying the meaning of key terms. Courts refer to this section to interpret ambiguous terms and ensure consistency in application.
  • Margin Notes and Side Notes:
    Margin notes and side notes are brief summaries or explanations provided alongside sections or provisions of a statute. While they are not part of the statutory text and do not carry legal authority, they can offer helpful guidance in understanding the content and purpose of specific provisions.
  • Context:
    Interpreting statutes requires consideration of the broader legal and factual context in which the statute operates. This includes examining related statutes, legislative history, judicial precedents, and societal norms relevant to the subject matter of the statute. Contextual analysis helps ensure that statutes are interpreted in a manner that is consistent with the overall legal framework and societal expectations.
  • Concluding Provisions:
    The concluding provisions of a statute, such as repeals, savings clauses, or transitional provisions, may clarify the intended effect of the statute on existing laws or rights. They provide guidance on how the statute is to be applied in practice and may influence the interpretation of specific provisions.

External AIDS/h2> External aids to the interpretation of statutes are resources or materials outside the statute itself that assist in understanding its meaning and application. These aids provide context, guidance, and supplementary information that can help clarify legislative intent and resolve ambiguities in statutory language. Here are some common external aids to the interpretation of statutes
  • Legislative History:
    Examining the legislative history, including committee reports, debates, and drafts, provides context and insight into legislative intent behind specific provisions.
  • Judicial Precedents:
    Judicial precedents, or prior court decisions interpreting similar statutes or legal principles, serve as persuasive authority in interpreting statutes. Courts may look to precedents to guide their interpretation and ensure consistency in the application of the law.
  • Maxims and Canons of Construction:
    Maxims and canons of construction are general principles or rules of interpretation that guide courts in resolving ambiguities and determining the meaning of statutory language. Examples include the ejusdem generis rule and the noscitur a sociis rule that involves interpreting words in a statute in light of the context in which they appear.
  • Contextual Analysis:
    Interpreting statutes requires consideration of the broader legal and factual context in which the statute operates. This includes examining related statutes, legal principles, societal norms, and contemporary events relevant to the subject matter of the statute.
  • Legal Dictionaries and Lexicons:
    Legal dictionaries and lexicons provide definitions and explanations of legal terms and concepts, helping to clarify the meaning of specific terms used in statutes.
  • Expert Testimony:
    In complex cases, courts may rely on expert testimony from legal scholars, practitioners, or subject matter experts to provide insights into the meaning and application of statutory provisions.
  • Treatises and Commentaries:
    Legal treatises and commentaries written by legal scholars and experts provide in-depth analysis and interpretation of statutory provisions, offering valuable insights into legislative intent and judicial interpretation.
  • Contemporaneous Materials:
    Contemporaneous materials, such as newspaper articles, government reports, and academic publications, can provide historical context and insight into the societal and political factors influencing the enactment of statutes.
  • Purpose and Objectives:
    Courts may consider the broader purpose and objectives underlying a statute when interpreting its provisions. This involves analyzing the legislative intent behind the enactment of the statute and interpreting its provisions in a manner that advances the statute's underlying goals and objectives.

General Principles Of Interpretation

Several principles guide the interpretation of words within a statute:
The Literal Rule
The first principle of interpretation is the literal or grammatical interpretation which means that the words of an enactment are to be given their ordinary and natural meaning. The text is interpreted as it is written, without delving into the legislative history or purpose.

The Mischief Rule
This historical principle focuses on the problem the statute aimed to address and interprets words in a way that effectively remedies that problem. The mischief rule involves identifying the problem or "mischief" that the statute was designed to address and interpreting the law in a way that suppresses the identified mischief and advances the remedy.

The Golden Rule
This principle allows for a slight departure from the literal meaning of words to avoid an outcome that would clearly be against the legislature's intent. The Golden Rule of interpretation is a method used in statutory interpretation to guide judges when the literal meaning of words in a statute leads to unreasonable or unjust results. Instead, they may choose an alternative interpretation that aligns with the overall purpose of the law.

Harmonious Construction
This principle seeks an interpretation that ensures all parts of the statute work together cohesively, avoiding inconsistencies. Harmonious Construction, also called Harmonization or Consistent Interpretation, reconciles conflicting provisions within or between statutes, ensuring all relevant provisions are upheld while maintaining legal coherence. It resolves conflicts arising from multiple or overlapping laws on similar subjects, guiding courts to interpret provisions to avoid contradictions and honor legislative intent.

The Statute should be Read as a Whole
The meaning of individual words and phrases should be derived by considering them within the context of the entire statute. The principle of interpreting statutes as a whole emphasizes considering the entirety of a statute rather than focusing solely on individual provisions. It suggests that the meaning of any particular provision should be understood in the context of the entire statute to discern the legislative intent accurately. This approach ensures that each provision is interpreted in harmony with the overall purpose and structure of the law, promoting consistency and coherence in statutory interpretation.

Construction ut res magis valeat quam pereat
It is a Latin Maxim means "let the thing prevail rather than perish". This principle favors interpretations that uphold the validity and effectiveness of the statute. It emphasizes that when interpreting statutes, courts should adopt a construction that gives effect to the purpose and intention of the law rather than allowing it to become ineffective or meaningless. This principle underscores the importance of interpreting statutes in a manner that upholds their intended function and serves the interests of justice.

Identical Expressions to Have Same Meaning
The principle that "identical expressions should have the same meaning" is a fundamental rule of statutory interpretation. It suggests that when a statute uses the same words or phrases repeatedly, those words or phrases should be interpreted consistently throughout the statute. This principle ensures uniformity and coherence in the interpretation of the law, preventing confusion or ambiguity that could arise from inconsistent meanings assigned to identical expressions within the same statute. It reflects the presumption that lawmakers intend for consistent meanings to apply to repeated language within a statute, promoting clarity and predictability in legal interpretation. Courts generally presume that the legislature intended the same meaning for identical expressions used throughout the statute.

Construction noscitur a sociis
Noscitur a sociis, a principle of statutory interpretation, means "it is known by its associates." Courts use this principle to determine the meaning of an ambiguous word or phrase within a law by considering the surrounding words and phrases. In essence, the meaning of a word is derived from the "company it keeps" within the statute. This helps ensure a consistent and logical interpretation of the law as a whole.

Construction ejusdem generis
Ejusdem generis, meaning "of the same kind," is a principle of legal interpretation used for statutes with lists. When a law lists specific items followed by a general term like "or others," the general term is interpreted to apply only to things similar to the listed items. This prevents the general term from being too broad and ensures the entire list has a cohesive meaning.

Construction expressio unius est exclusio alterius
The legal principle of "expressio unius est exclusio alterius," Latin for "the expression of one thing is the exclusion of the other," is employed in statutory interpretation to guide courts when interpreting statutes. This principle suggests that when a law enumerates specific items or categories, the omission of others implies the intentional exclusion of those omitted. In other words, if a statute explicitly mentions certain elements, but not others, it is presumed that the legislature intended to exclude the omitted elements from the scope of the law. Courts apply this principle to avoid expanding the statute's application beyond what was expressly stated, thereby respecting the legislature's intent and maintaining consistency in statutory interpretation.

Construction contemporanea expositio est fortissimo in lege
The Latin maxim "Construction contemporanea expositio est fortissimo in lege" (a historical interpretation is the strongest in law) conveys that the interpretation of a law as consistently understood and applied over time holds great importance. This principle suggests that when courts interpret statutes, especially older ones, they should give weight to how the law was understood when it was enacted. This helps maintain the original intent of the law and avoids imposing modern interpretations on potentially outdated language. By prioritizing historical interpretation, courts uphold the stability and continuity of legal application, respecting precedent and ensuring adherence to the rule of law.

Meaning Of Construction

Construction, in strict sense, is the process by which the court assign the meaning to the ambiguous provision which is beyond the letter of law for the purpose to resolve the inconsistency. The judges after taking into consideration the factual circumstances before the court give a particular meaning to the expression or word or phrase in question.[2] General principles of interpretation for constructive words involve understanding how certain terms or phrases are constructed within legal contexts. Constructive words are those that imply a legal fiction or create a legal relationship. Additionally, the principle that identical expressions within the statute should be given the same meaning ensures consistency and coherence in interpretation. Beyond individual words, broader principles guide the interpretation of a statute as a whole.

Distinction Between Interpretation And Construction

Interpretation and Construction are terms often used interchangeably in legal contexts, but they have distinct meanings and applications. According to Cooley, interpretation is an art of finding out the true sense of trhe woerds, that is, the sense which their author intended to convey. On the other hand construction is the drawing of conclusion from the statute which lie beyond the direct expression of the text. Conclusions which are thus drawn are within the spirit though not within the letter of the law.
S.N. Feature Interpretation Construction
1 Concept Interpretation refers to the process of determining the meaning of the words and phrases used in a statute, legal document, or any written text. It focuses on discovering the intent of the legislature or the parties involved at the time the document was created. Construction goes a step further than interpretation. It involves applying the determined meaning of the words and phrases to specific situations, especially when there is ambiguity, vagueness, or when the application to a specific case is not clear from the text alone.
2 Focus Focuses on discovering the meaning of the text. Focuses on applying the meaning to specific situations.
3 Ambiguity Deals with clear and unambiguous text. Deals with ambiguous or unclear text and its application.
4 Objective Aims to find the intent of the words. Aims to determine the legal effect and how it applies to real-life scenarios.
5 Scope Narrower, dealing only with the text. Broader, dealing with application and implications.

Strict Interpretation Of Penal Laws

In the context of penal laws, a strict interpretation refers to the narrow and precise understanding of criminal statutes. The principle of strict construction of penal laws dictates that any ambiguity or uncertainty in the language of a criminal statute should be resolved in favor of the accused. This approach ensures that individuals are not unfairly punished for conduct that is not clearly prohibited by law. Judges avoid expanding the scope of criminal liability beyond what is expressly stated in the statute, and any doubts or ambiguities are resolved in favor of the accused. The rationale behind strict interpretation of penal laws is rooted in the principles of justice, fairness, and the presumption of innocence.

Rational For Strict Interpretation

  • Fair Notice:

    Criminal laws define offenses and their corresponding punishments. Strict interpretation ensures individuals have clear and unambiguous notice of what conduct constitutes a crime. This prevents citizens from being punished for actions they could not reasonably know were illegal.
  • Presumption of Innocence:

    The criminal justice system operates on the presumption of innocence until proven guilty. Strict interpretation upholds this principle by requiring the prosecution to prove every element of the offense beyond a reasonable doubt. Ambiguous laws create uncertainty, potentially leading to wrongful convictions.
  • Proportionality:

    Penal laws should be proportional to the severity of the offense. Strict interpretation discourages courts from expanding the scope of criminal laws to encompass minor infractions, ensuring a more even-handed application of punishment.
  • Separation of Powers:

    Strict interpretation safeguards the separation of powers by limiting judicial intervention in the legislative process. The legislature is responsible for defining crimes and their punishments. Courts interpreting these laws narrowly avoid encroaching on legislative authority.

Applying Interpretation Of Statutes

When a penal statute is ambiguous, courts employ various methods of strict interpretation:
  • Plain Meaning Rule: Courts prioritize the ordinary and natural meaning of the words used in the statute. Legal jargon and technical terms are interpreted with strict attention to their established definitions.
  • Lenity Rule: When two or more reasonable interpretations of a penal statute exist, the court favors the interpretation that benefits the defendant. Ambiguity is resolved in favor of leniency.
  • Focus on Legislative Intent: Courts attempt to discern the original intent behind the statute when it was enacted. Legislative history, committee reports, and debates surrounding the law's passage can be used as reference points.
  • Limitations of Strict Interpretation:
    • Outdated Laws: Strict adherence to the original meaning of a law can create difficulties when social norms or technology have evolved. An overly narrow interpretation might not reflect the current societal context.
    • Public Safety Concerns: Strict interpretation could potentially hinder law enforcement's ability to address emerging threats if the existing legal framework lacks clear provisions.
    • Legislative Drafting Flaws: Poorly drafted statutes with vagueness or ambiguity can pose challenges, regardless of the interpretive approach.

Strict Interpretation Of Taxation Laws

In taxation law, strict interpretation means precisely understanding tax statutes to ensure consistency. Courts strictly adhere to statutory language, limiting tax liability to what's explicitly stated and preventing overreach by tax authorities. This upholds the rule of law, protecting taxpayers from arbitrary taxation. Clear statutory language fosters transparency and compliance.

Rationale For Strict Interpretation

  • Fair Notice: Tax laws establish the government's right to collect revenue and define the obligations of taxpayers. Strict interpretation ensures taxpayers have clear and unambiguous notice of what income or activity is taxable. Unclear laws can lead to unfair application and disputes.
  • Burden of Proof: The burden of proof in tax matters typically rests with the government to demonstrate that a specific tax applies to a taxpayer's situation. Strict interpretation reinforces this principle by making it harder for the government to impose taxes based on vague or overly broad legal language.
  • Equality before the Law: Strict interpretation promotes equal application of tax laws across all taxpayers. Ambiguous laws can lead to inconsistent interpretations and potentially benefit some taxpayers over others.
  • How Strict Interpretation Works: When a tax law is unclear, courts might employ various methods for strict interpretation
    • Plain Meaning Rule: Courts prioritize the ordinary and natural meaning of the words used in the statute. Legal jargon and technical terms are interpreted with strict attention to their established definitions.
    • Taxpayer Benefit Rule: If two or more reasonable interpretations of a tax statute exist, the court favors the interpretation that benefits the taxpayer. Ambiguity is resolved in favor of a lower tax burden.
    • Focus on Legislative Intent: Courts may attempt to discern the original intent behind the statute when it was enacted. Legislative history and debates surrounding the law's passage can be used as reference points.
Case Laws
Maqbool Hussain Vs. State of Bombay[3]
In the following case the appellant Maqbool Hussain, a citizen of India, on arrival at an airport did not declare that he had brought gold with him. Gold, found in his possession during search in violation of government notification, was confiscated under Section 167(8), Seas Customs Act, 1878.

He was charged under Section 8, Foreign Exchange Regulation Act, 1947 also. The appellant pleaded that his trial under the act of 1947 was violative of Article 20(2) of the Constitution relating to double jeopardy (risk) as he was already punished for his act by way of confiscation of his gold. It was held by the Supreme Court that the Sea Customs Authority is not a court or a judicial tribunal and the adjudging of confiscation or the increased rate of duty of penalty under the Sea Customs Act was not a prosecution. Consequently, his trial under the Act of 1947 was valid.

Motipur Zamindary Company Pvt. Ltd. v. State of Bihar[4]
The Supreme Court of India decided in Motipur Zamindary Company Pvt. Ltd case that sugar cane sold by the company was not exempt from sales tax under a government notification exempting "green vegetables." The court rejected the company's arguments that sugar cane was a green vegetable and that the company itself wasn't a dealer under the Bihar Sales Tax Act.

Poppatlal Shah v. State of Madras[5]
In the following case, the Supreme Court observed that it is a settled rule of construction that to ascertain the legislative intent, all the constituent parts of a statute are to be taken together and each word, phrase, or sentence is to be considered in the light of the general purpose and object of the Act itself.

State of UP v. Kores (India) Pvt. Ltd.[6]
The question was whether carbon paper was within the meaning of a notification issued by the appellant under Section 3-A of the U.P. Sales Tax Act, 1948. The Supreme Court held that carbon paper was not a paper within the meaning of the notification. The term paper should be understood in its popular sense.

Alamgir v. State of Bihar[7]
The appellant was charged under Section 498 of IPC i.e. the crime of enticing or taking away or detaining with criminal intent a married woman. In the present instance the married women was living with the appellant voluntarily. The question was whether he was detaining her. The Supreme Court observed that the section contemplates four classes of cases, viz., taking or enticement or concealment or detention. Since the first three categories are inapplicable in the present instance, the liability of the accused depended on whether the married woman was being detained by him. It was held that the provision sought to remedy the mischief of depriving the husband of the company of his wife and consequently, it was enacted with the object of protecting the rights of the husband.

Ramjit Udeshi v. State of Maharashtra[8]
In this case, the appellant was convicted under section 292, IPC by the High Court for selling an obscene book. The Supreme Court of India addressed obscenity in the context of free speech. The court, while upholding the conviction for selling D.H. Lawrence's "Lady Chatterley's Lover," established a test for obscenity. Material lacking a social purpose or literary merit and appealing solely to prurient interests wouldn't be protected free speech.

M.Pentiah v Veeramallappa[9]
This case deals with the question of whether members of a municipal committee in India remained in office after the law governing the committee was repealed and replaced with a new law. The appellant prayed for a writ of quo warranto. The Supreme Court, agreeing with the prayer, held that if more than one construction were possible the one which narrower and failed to achieve the object of the act should fail. The Act should be so interpreted as to avoid absurdity.

In simple terms, The Supreme Court ruled in favor of the appellant's writ of quo warranto. Consequently, they agreed that the members in question were no longer legally entitled to their positions.

Principle of Interpretation
The court applied the principle that when a statute (law) is ambiguous and open to multiple interpretations, the interpretation that best achieves the law's purpose and avoids absurdity should prevail.

The court likely reasoned that if two interpretations were possible, a narrow interpretation that hinders the law's objective should be rejected. They likely argued that the law intended a smooth transition between the old and new system, and a narrow interpretation could create a gap in governance or leave the positions ambiguously filled.

Interpretation of statutes is an ongoing process that ensures the law remains relevant and adaptable. By utilizing established principles and various aids, courts strive to understand the will of the legislature and apply the law in a just and meaningful way.

In conclusion, the interpretation of statutes is a nuanced and multifaceted endeavor that requires careful consideration of various factors and principles. By employing a comprehensive approach that combines textual analysis with historical context and legal reasoning, courts can effectively discern the will of the legislature and uphold the rule of law.

End Notes:
  1. Prof. T. Bhattacharya: The Interpretation of Statutes 7th Ed. 2009
  2. Rashi Choudhary: Interpretation of Statutes: A Complete to an Aids to Interpretation (2020), Legal Services of India E-Journal;
  3. Maqbool Hussain Vs. State of Bombay, AIR 1953 SC 325
  4. Motipur Zamindary Company Pvt. Ltd. vs. State of Bihar, AIR 1962 SC 660
  5. Poppatlal Shah Vs. State of Madras, AIR 1953 SC 274
  6. State of UP v. Kores (India) Pvt. Ltd., AIR 1977 SC 132
  7. Alamgir v. State of Bihar, AIR 1959 SC 436
  8. Ramjit Udeshi v. State of Maharashtra, AIR 1965 SC 881
  9. M.Pentiah V. Veeramallappa, AIR 1961 SC 1105

Award Winning Article Is Written By: Mr.Syed Mohd Osama Azam, LL.B. Second-year Student at Saifia Arts, Commerce & Law College, Barkatullah University, Bhopal
Email: [email protected] , Ph no: +91 7000657720
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Authentication No: JN417778437625-25-0624

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