The literal rule is a method courts use to interpret laws by sticking to the exact words of a statute, giving them their ordinary, natural meaning—no matter the consequences or the broader purpose of the law. If the language of the statute is clear, judges must apply it as written, even if it leads to an outcome that seems unfair or contrary to the law’s intended purpose.

This rule is based on the idea that the best way to understand what lawmakers intended is to focus on the precise words they used. While this approach ensures consistency and predictability in legal interpretation, it can sometimes produce rigid or impractical results, especially in complex situations.

Introduction
A statute represents the will of the legislature, guiding how governments operate. The executive branch must follow it, and courts must apply it when delivering justice. However, since laws are written in words that may sometimes be unclear or open to multiple interpretations, judges often need to determine their true meaning. Over time, courts have developed certain rules of interpretation to help with this process.

Many statutes include a Statement of Objects and Reasons or a Preamble, which help in understanding the intended meaning of their provisions. When judges interpret laws, they often refer to the literal meaning of words, looking for their plain or natural sense. If the meaning is clear from the text itself, no additional interpretation is needed.

When courts interpret statutes, their primary duty is to give effect to the intent of the lawmakers, and the first step in doing so is examining the language used in the law itself. Since statutes are the official expression of legislative intent, the exact words used in them carry legal authority. Interpretation refers to the process by which courts determine what the legislature intended based on the wording of the statute, while construction sometimes goes beyond the words to resolve ambiguity. Though the terms "interpretation" and "construction" are often used interchangeably, they are slightly different concepts.

Background:
Interpretation is the method by which the true sense or the meaning of the word is Understood. The meaning of an ordinary word of the English language is not a question of law. According to Gray, the process by which a judge constructs from the words of a statute book, a Meaning which he either believes to be that of the legislature, or which, he proposes to attribute

To it is interpretation. Salmond describes interpretation or construction as the process by which Courts seek to ascertain the meaning of the legislature through the medium of authoritative forms In which it is expressed. Truly and literally speaking, interpretation differs from construction. According to Cooley, interpretation differs from construction in that the former is the art of Finding out the true sense of any form of words; construction on the other hand, is the drawing of Conclusions respecting the subjects that are beyond the direct expression of the text.

The term 'construction' has been explained in CWT vs. Hashmatunnisa Begum to mean that something More is being got out in the elucidation of the subject-matter than can be got by strict Interpretation of the words used. Judges have set themselves in this branch of the law to try to Frame the law as they would like to have it. The intention of the Legislature is primarily to be Gathered from the language used which means that attention should be paid to what has been Said. As a consequence a construction which requires for its support addition or substitution of Words or which result in rejection of words as meaningless has to be avoided.

Literal Rule Of Interpretation:
Interpretation of statutes is of two types –they can de distinguished as "literal" and "functional".The Courts have laid down that the Interpretation of the statutes must be in Accordance with the literal meaning of the words and expressions read in the light of the "Statement of Objects and Reasons and the Preamble" of the Act".The Primary Rule of Interpretation of Statutes is called "Literal Interpretation" or "Literal Construction". It is also Known as "Plain Rule of interpretation". In this form of interpretation the "words" used in the Statute are construed according to their "literal" meaning or according to the popular and Dictionary meaning of the term, in other words its plain sense.

Chief Justice Jervis in Abley Gale has explained the expression 'literal meaning'.

He points out that "if the precise words Used are plain and unambiguous, in our judgment we are bound to construe them in their Ordinary sense even though it too leads in our view of the case to an absurdity or manifest Injustice. The words of a statute are to be first understood in their natural, ordinary or popular Sense and phrases and sentences are construed according to their grammatical meaning, unless That leads to some absurdity or unless there is something in the context, or in the object of the Statute to suggest the contrary. The tendency is that by doing so, the courts give effect to the Intention of the Parliament and the presumption is that the words themselves do, in such a case it Is best to declare the intention of the law giver.

It is a rule of construction of statutes that in the first instance the grammatical sense of the word Is to be adhered to.The words of a statute must prima facie be given their ordinary meaning. Where the grammatical construction is clear and manifest and without doubt, that construction Ought to prevail unless there be some strong and obvious reason to the contrary. In other words The best possible interpretation of a statute would be to give its plain meaning.

When the Language of the statute is clear and unambiguous it is not necessary to look into the legislativeintent or object of the Act.22 It is when the language is vague that the legislative's intention is to be taken into consideration. There is no room for construction if there isn't any ambiguity. If the language of a statute is clear and unambiguous the court must give effect to it and it has no right to extend its operation in order to carry out the real or supposed intention of the legislature.

When the language is not only plain but admits of but one meaning the task of interpretation can hardly be said to arise. The duty of the court of law is simply to take the statute as it stands, and to construe its words according to their natural significance. If the words of the statute are in themselves precise and lucid, then no more can be necessary than to expound those words in their natural and ordinary sense. A restrictive and exhaustive definition should be expanded or made extensive to embrace things which are strictly not within the meaning of the word as defined.

It doesn't look beyond the written words. If the words given in the statute are lucid and explicit, it is not for the judges to go beyond that language or words to try and establish what the legislative might have meant by using that word. It is also known as "Grammatical Interpretation" .The Courts have to follow this principle even if it results in irrationality or even if it is contrary to the policy or intention of legislature. It doesn't look beyond the litera legis which means letter of legislation.It just looks at what law says. Words and phrases are to be construed by the courts in their ordinary sense, and the ordinary rules of grammar and punctuation have to be applied.

If, applying this rule, a clear meaning appears, then this must be applied, and the courts will not inquire whether what the statute says represents the intention of the legislature. In order to determine the literal meaning of a statute the courts have to ascertain the ordinary meaning of a word in a statute by referring to a dictionary or scientific or any other technical works where the words have been used. This rule is also widely followed in India. It is an elementary principle of the construction of statutes that the words have to be read in their literal sense.

Thus, generally speaking, words and expressions would be given their plain and ordinary meaning which cannot be cut down or curtailed unless they in themselves are clearly restrictive. If the words of the statute are clear and unambiguous, it is the plainest duty of the court to give effect to the natural meaning of the words used in provision. When the meaning of the words is plain, it is not the duty of Courts to busy themselves with supposed intentions.

It, therefore, appears inadmissible to consider the advantages or disadvantages of applying the plain meaning whether in the interests of the prosecution or accused. In constructing a statutory provision, the first and the foremost rule of construction is the literary construction. All that we have to see at the very outset is what that provision says. If the provision is unambiguous, and if from that provision, the legislative intent is clear, there is no need to call into aid other rules of construction of statutes. Absoluta sentantia expositore non indigent- plain words need no exposition. Such language best declares, without more, the intention of the law-giver, and is decisive of it.

Rule To Be Follow:
So far as literal rules of interpretation are concerned, they tend to operate restrictively. The Following rules are to be kept in mind. These are the subsidiary rules to apply literal rule of Interpretation.

Ejusdem Generis (clasula generalis de residue non ea complecitur,quae non ejusdem generis Cum,iis qua speciatim dicta fuerint)-When particular words forming part of the same class or Same category are followed by general words then the general words must be construed in the Context of the particular words. It means of the same kind or nature. According to this principle The words of a statute are to be understood in their context especially when general words are Used in a summarizing or comprehensive manner.

If there is some kind of ambiguity the word Has to be interpreted in the light of words used earlier. If a man tells his wife to go to the market To buy vegetables, fruits, groceries and anything else she needs, the 'anything else' would Taken to mean food and grocery items due to the rule of ejusdem generis and not cosmetics or Other feminine accessories. In Workmen of Dimakuchi v. Dimakuchi Tea Estate the problem Arose regarding the interpretation of "any person" whose services is not like worker or employer Cannot be considered as 'workman'. So the rule of ejusdem generis was applied.

When a Particular word is followed by general words the rule of interpretation is that these common Words are limited to the same species or the same category as the particular word. In State of Madras v. Shantabai61 the question arose whether or not university is a 'State'. The court held That it is not a State. The expression "all other articles whatsoever", must be interpreted to mean Only article of the same kind as those expressly dealt with by the statute. The court will not Apply ejusdem generis. But it will try to interpret something of the same kind.

Casus Omissus-A point unprovided for by a Statute .The Casus Omissus rule provides that Omissions in a statute cannot be supplied by judicial construction.

This rule signifies that Omissions in a statute cannot as a general rule be supplied by interpretation .The Courts have the Liberty only to remedy the logical defects in words and phrases used in the statute and the Intention of the legislature. The court prefers the interpretation in accordance with the words used without adding a new word. In Parkinson v. Plunton65 while interpreting catering establishment in Wages Act, 1943 the House of Lords preferred the interpretation in accordance with the language used therein and did not extend to cover the boarding and lodging. The approach of the court is not to apply certain words which are not found in the statute.

However, if the intention of the legislature is faulty, either too broad or too narrow, the Courts are bound to accept them as they are given and they cannot either add, alter, modify, deduct or amend from the given Statute, as such an action would amount to legislation rather than construction or interpretation. There is no scope for importing into the statute words which are not there. Such importation would be, not to construe, but to amend the statute. Even if there be a casus omissus, the defect can be remedied only by Legislation and not by judicial interpretation.

The duty of the Court to try and harmonise the various provisions of an Act passed by the legislature, but not to amend the words used by legislature. It is certainly not the duty of the Court to stretch the words used by the legislature to fill the gaps or omissions in the provisions of an Act, as given in Hiradevi v. District Board.

The purpose of the Legislature has to be established from the exact words of the Statute, where they arise in their accurate and precise form. But if the same is implied in vague and ambiguous language, the Courts may seek the aid of every reasonable and permissible aids to interpretation. This principle of Casus Omissus cannot be supplied by the Court except in case of clear necessity and when the reasons for it are found in the four corners of the Statute itself. In the case of Commissioner of Income Tax, Central Calcutta v. National Taj Traders.

Expressio unius est excusio alterius-The express mention of one person or thing is the exclusion of another. Where the statutory language is plain and the meaning clear, there is no scope for applying the rule. If a given word or phrase is competent of two interpretations, the express mention of one of the possibilities on a similar context excludes the other possibility. This rule may be used to denote the aim or intention of the Legislature, although it would not be safe to regard it as an obligatory rule of law. In the words of Lopes, L.J this maxim means "a valuable.

Present Position In India:

• Kanai Lal v. Paramnidh: The court stated, "it must always be borne in mind that the first and primary rule of construction is that the intention of the Legislature must be found in the words used by the legislature." It also added, "When the material words are capable of two constructions, one of which is likely to defeat or impair the policy of the Act whilst the other construction is likely to assist the achievement of the said policy, then the courts would prefer to adopt the latter construction."
  This case dealt with the ejection of ka tenants under the provisions of the Calcutta Theka Tenancy Act, 1949.
• S.A. Venkataraman v. The State: This case dealt with Section 6 of the Prevention of Corruption Act. It focused on taking a sanction from an appropriate authority and considered only presently working employees as employees, excluding retired individuals.
  The court stated, "In construing the provisions of a statute, it is essential for a court, in the first instance, to give effect to the natural meaning of the words used therein, if those words are clear enough."
• Tej Kiran Jain v. N. Sanjeeva Reddy: Regarding Article 105(2) of the Constitution, which states that "no member of the Parliament shall be liable to any proceeding in respect of anything said or any vote given by him in Parliament," the Supreme Court held that the Article means exactly what it states in plain language.
• P.V. Narshima Rao v. State (Central Bureau of Investigation): When Mr. P.V. Narshima Rao was Prime Minister, the government faced a no-confidence motion, which was later defeated. However, some members were accused of bribery. The President of Rashtriya Mukti Morcha filed a complaint alleging corruption charges against P.V. Narshima Rao with the CBI.
  The Supreme Court, by a majority of three judges, held that a member who voted in Parliament after receiving a bribe could not be prosecuted, as his prosecution would be a proceeding in respect of a vote given by him and was thus barred by Article 105(2) of the Indian Constitution.
• Ramavtar Budhaiprasad v. Assistant Sales Tax Officer: The Supreme Court was faced with the interpretation of the word "vegetable" in the C.P. and Berar Sales Tax Act, 1947. The question was whether "vegetables" included betel leaves. The Court held that "being a word of everyday use, it must be construed in its popular sense." It ruled that betel leaves were excluded from the definition of vegetables.
• Forest Range Officer v. Khushboo Enterprise: The question was whether sandalwood oil is "wood oil" as used in Section 2(f) of the Kerala Forest Act, 1961. A technical dictionary defined wood oil as a natural product of the forest. The Court held that sandalwood oil qualified as wood oil.
• Vemma Reddy Kumarswamy Reddy v. State of Andhra Pradesh: This case involved a dispute over excess land possessed by the appellant, which was surrendered and contained a cashew-nut plantation. The trees on the surrendered land were fruit-bearing. The Court stated that if the wording of a statute is plain and unambiguous, then the primary rule of interpretation should be applied. The Andhra Pradesh Land Reforms (Ceiling on Agricultural Holdings) Act, 1973 was referred to for land compensation.

Merits:

• Literal rule of interpretation is a traditional approach, often advocated by jurists who support the plain meaning rule, arguing that it prevents courts from intervening in legislative or political matters.
• It ensures consistency in interpretation, as ordinary people and lawyers do not have extensive access to secondary sources.
• Extrinsic evidence should not be allowed to alter the words used by a testator or their meaning.

Criticism:
There are certain defects of the literal rule of interpretation. The defects may be of two types Logical defect which constitutes of ambiguity, inconsistency and incompleteness and the second Type is absurdity or irrationality.

Ambiguity
occurs where a term or an expression used in a Statute has not one but various meanings, and it is not clear which one particular meaning it Represents at
which particular context or place. So here the court will have to go beyond the Statute and yet stick to the same literal words of the statute to ascertain its
meaning.

Also the Ambiguity sometimes is "syntactic"84 which means the vagueness arises from words like "or","and", "all" and other such words. For example if a punishment for a certain crime is "fine Or imprisonment or both",
the court can imprison the accused or impose a fine or impose a fine As well as imprison him. If the language of the statute is clear and unambiguous, the Court Cannot discard the plain meaning, even if it leads to an injustice.

The words cannot be Understood properly without the context in which it is used. The strict adherence to this principle May cause injustice and sometimes it might give results which are quite contrary to general Intention of the statute or common sense.86 In case there is some lacuna or omission in the statute Which prevents it from giving a complete idea, or it makes it logically incomplete, it is the duty Of the court to make up the defect by adding or altering something, but the court is not allowed to Do more than that.

It is permissible only in cases where the statutes are inapplicable in their Present form, which is incomplete. For the change, either alteration or addition the court looks Into the matters which will probably help it in ascertaining the intention of the legislature.

It is Not necessary that judges would always find some or the other means to help them in cases of Defective texts. There will be some cases where they might find nothing of this kind. They may Ascertain the intention of the legislature which presumably, would have had the defect come to Notice. One of the problems of literal rule is that it breeds absurdity. Sometimes the court might Ascertain a certain meaning to the statute which was never the intention of the legislature.

The Traditional rule of literal interpretation forbids the court to attach any meaning other than the Ordinary one. It closes the doors for any type of judicial innovation, thereby imposing a Restriction on the Courts. Since the rule is to stick to the exact words of the statute few lawmen Say that it is like imposing a rule even when you know that it is not right. If the court applies Literal rule and feels that the interpretation is morally wrong then they cannot avoid giving the Interpretation.

Conclusion.
Literal rule of interpretation is the primary rule. Under this rule of interpretation the Courts Interpret the statutes in a literal and ordinary sense. They interpret the words of the statute in a Way that is used commonly by all. It is incumbent on the court to use the grammatical meaning. The statutes should be construed in such a manner as though there is no other meaning except the Literal meaning. It is an old and traditional rule of interpretation.

It is used not only in England Where it originated but also in India. The Courts while interpreting statutes have to keep few Things in mind. It must realize that a provision is ambiguous only if it contains a word or phrase Which has more than one meaning. If the interpretation is open to different meanings in one Context it is ambiguous but if it is susceptible to different meaning in different contexts it is Plain. The art of correct interpretation would depend on the ability to read what is stated in plain Language, read between the lines, read 'through' the provision, examining the intent of the Legislature and call upon case laws and other aids to interpretation.

Bibliography.:

• Maxwell, P. (1985). On the Interpretation of Statutes.
• Zander, M. (2015). The Law-Making Process.
• Millett, L. (2011). "The Interpretation of Statutes: A Historical Overview." Law Quarterly Review, 127, 250–276.
• Elliott, C. & Thomas, R. (2017). Public Law. 3rd ed. Oxford University Press.
• Salmond, J.W. (1924). The Law of Tort. 11th ed. Stevens & Sons.

Written By:

• Mrs. Prajakta Vijay Awhale - L.L.M 1st Year , Semester 2nd
• Mr. Abhishek Vikas Mane - L.L.M 1st Year , Semester 2nd
  
  Under the Guidance of Asst. Prof. Neelam Mam (Asst. Prof. Modern College)