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Introduction to Statutory Interpretation

Utkal Contractors & Joinery (P) Ltd. v. State of Orissa, 1987 AIR SC 2310

ISSUE:

Whether the contract of the petitioner with the Government stands rescinded from the date of notification issued to enforce the Orissa Forest Produce (Control of Trade) Act, 1981?

RULE:

General words and phrases, however wide and comprehensive they may be in literal sense, must be usually construed as being limited to actual objects of the Act.

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Introduction to Statutory Interpretation

Vivek Narayan Sharma v. Union of India, WP(C) 906 of 2016

ISSUE:

Whether the 8th November, 2016 notification was properly implemented under Section 26(2) of the RBI Act,1934 by the Central government, and whether its continuation meets the test of proportionality?

Whether the word “any” in section 26(2) of RBI Act 1934 should be given a narrow or a wider interpretation?

Whether excessive delegation of legislative power has been made under section 26(2) of the RBI Act,1934?

Whether the notification’s implementation suffers from procedural or substantive unreasonableness, and what is the scope of judicial review in fiscal and economic policies like demonetization?

RULE:

An interpretation that advances the purpose of the Act and ensures its smooth and harmonious working should be adopted. Any interpretation leading to absurdity, confusion, contradiction or undermining the basic scheme and purpose of the enactment, must be avoided.

The primary task of the Court in interpreting a statute is to ascertain the intention of the legislature, both actual and imputed.

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Introduction to Statutory Interpretation

Union of India v. Ranbaxy Laboratories Ltd. (2008) 7 SCC 502

ISSUE:

Whether the exemption notification dated 29th August 1995 apply only to drugs manufactured by 31st October 1999, or does it also cover drugs sold after that date?

Whether the manufacturer could be held responsible for the sale price of drugs sold after 31st October 1999, despite the fact that they were manufactured within the exemption period?

RULE:

Doctrine of Purposive Construction: Laws and notifications must be interpreted to fulfill their practical purpose and achieve reasonable objectives. Interpretation should avoid outcomes that are impractical or absurd.

Legislative Intent: The interpreter must assume that the legislature acted in good faith, seeking to achieve reasonable goals. The focus should be on the intent the legislature would have had, had they acted reasonably rather than on their subjective intent.

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