ISSUE:
Whether the term “individual” in Section 16(3) of the Indian Income-tax Act, 1922, includes a female, thereby permitting the inclusion of a mother's minor children’s income from a partnership in her total income?
RULE:
The Mischief rule laid down in Heydon’s Case examines the law's state before the statute was passed, the mischief or gap the statute addresses, Parliament’s remedy to cure the mischief, and the intended purpose behind the remedy.