PROJECT ON

LITERAL RULE: A TOOL FOR STATUTORY

Submitted To

Mr.S.Bala Shanmugam
(Associate professor in Interpretation of Statutes)

By
P.Prashanna Guruparan
III year B.A.LL.B (Honrs)
(Reg no.BA0150032)

1|Page
 ACKNOWNLEDGMENT

At the outset, I take this opportunity to thank my Professor Mr.S.Bala

Shanmugam from the bottom of my heart who has been of immense help during

moments of anxiety and torpidity while the project was taking its crucial shape.

Secondly, I convey my deepest regards to the Vice Chancellor Arun Roy

and the administrative staff of TNNLS who held the project in high esteem by

providing reliable information in the form of library infrastructure and database

connections in times of need.

Thirdly, the contribution made by my parents and friends by foregoing their

precious time is unforgettable and highly solicited. Their valuable advice and

timely supervision paved the way for the successful completion of this project.

Finally, I thank the Almighty who gave me the courage and stamina to

confront all hurdles during the making of this project. Words aren’t sufficient to

acknowledge the tremendous contributions of various people involved in this

project, as I know ‘Words are Poor Comforters’. I once again wholeheartedly and

earnestly thank all the people who were involved directly or indirectly during this

project making which helped me to come out with flying colours.

2|Page
 DECLARATION

I, P.Prashanna Guruparan do hereby declare that the project

entitled “LITERAL RULE: A TOOL FOR STATUTORY

INTERPRETATION” submitted to Tamil Nadu National law school in

partial fulfillment of requirement of award of degree in undergraduate in

law is a record of original work done by me under the supervision and

guidance of Professor Mr.S.Bala Shanmugam, Department of

Interpretation of Statutes, Tamil Nadu National law school and has not

formed basis for award of any degree or diploma or fellowship or any

other title to any other candidate of any university.

(P.Prashanna Guruparan)
B.A., LL.B (Hons)

3|Page
 LITERAL RULE: A TOOL FOR STATUTORY
INTERPRETATION

INDEX:

CHAPTER I
Interpretation:
Rules Associated With Rule Of Interpretation:

CHAPTER II
Literal Rule of Interpretation
Appraisal of the Principle
Merits
Present Position in India

CHAPTER III
CRITICISMS OF THE LITERAL RULE OF INTERPRETATION

CHAPTER IV
Golden Rule of Interpretation
Rule of Harmonious Construction
Rule of Beneficial Construction:

CHAPTER V
CONCLUSION:

4|Page
RESEARCH QUESTIONS:

1. What are the rules associated with Rule of Interpretation?

2. What is the position of this method of interpretation in India?

3. Whether the plain rule of interpretation is really fool proof?

4. If not what are the other rules of interpreting statutes and how are they better than the

plain rule of interpretation.

5|Page
 LITERAL RULE: A TOOL FOR STATUTORY
INTERPRETATION

INTERPRETATION:

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 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 its interpretation. Salmond describes interpretation or construction as the process by which the

court seeks to ascertain the meaning of the legislature through the medium of authoritative forms

in which it is expressed.

CHAPTER I

Rules associated with rule of interpretation:

Ejusdem Generis:-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 words1.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

1
A.N SAHA,, MITRAS LEGAL AND COMMERCIAL DICTIONARY 257 (5th ed1994).

6|Page
vegetables, fruits, groceries and anything else she needs, the ‘anything else’ would be 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 Estate2 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 word3. In State of Madras v. Shantabai4 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.5

Casus Omissus: The Casus Omissus rule provides that omissions in a statute cannot be supplied

by judicial constructions6. 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

Plunton7 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.

2
(1958)1LLJ500S.C
3
Chipman JohnGRAY NATURE AND SOURCES OF LAW, 176(2 nd edn.).
4
AIR 1958 SC 532
5
Ujjambai v State of Uttar Pradesh. AIR 1962 SC 1621
6
N.Mani Tripathi, ,JURISPRUDENCE-LEGAL THEORY 253 (17 th ed Allahabad Law Agency.
7

7|Page
 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. It is not duty of the Court to stretch the words used by the

legislature to fill the gaps or omissions

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 rule8. 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 servant but a dangerous master9”. Section 5 of the Transfer of Property Act, 1882

defines “transfer of property”, which means, “an act by which living persons conveys property,

in present or future, to one or more other living persons or to himself in and one or more

otherliving persons and to “transfer property” or to himself is to perform such act.”.

The next paragraph provides that in this section “living person” includes a company or

association or body of individuals whether incorporated or not .This clearly provides that “living

person” not only means an individual or human being but can also refers to a company or

association or body of individuals whether incorporated or not .However this rule may not

always provide the answer to problems of construction. It is often the result of inadvertence or

8
N.MANI TRIPATHI, ,JURISPRUDENCE-LEGAL THEORY 253 (17 th ed Allahabad Law
Agency,Faridabad,2006).
9
70Coluhoun v. Brooks (1886)21 Q.B.D 52

8|Page
accident that this principle is applied and the maxim ought not to be applied when its application,

having regard to the subject matter to which it is to be applied, leads to inconsistency or

injustice. This maxim is also not used to extend the operation of a statute beyond the operation of

a statute beyond the provision that it actually makes, e.g. a law enacted by Parliament for A,

what is already a law for A and others, the new law will not change the law for others.

CHAPTER II

Literal Rule of Interpretation:

The primary rule of interpretation of statutes is called “Literal Rule of Interpretation”. 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 v

Gale10 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. This is given in the Latin term verbis legis non est recelendum, which means from the

words of law there should be no departure.

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. Interpretation of a statute would be to give its plain meaning language of

the statute is clear and unambiguous it is not necessary to look into the legislative.

10
20 L.J.C.P (N.S) 233 (1851).

9|Page
 It is not necessary to take 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.

In the case of Deepak Aggarwal v Keshav Kaushik & Ors11 the interpretation of the

word has been was the issue. Art of the Constitution of India held that

‘A person shall only be eligible to be appointed as a District Judge if he has been, for not less

than seven years, an advocate or pleader, and is recommended by the High Court for appointment’

The three judges Bench of Supreme Court held that it is clear from the expression “has

been” that the present continuous tense is used for a position which began sometime in the past

and is still continuing, and therefore such person must, with the requisite period, still be

continuing as an advocate on the date of his application.

In the case of Healthways Dairy Products Co. Regd., Gauhati Vs. Union of India the

issue whether condensed skimmed milk will be included under condensed milk for tax

exemption where the SC held that unless other specified in the statute separately, the condensed

skimmed milk is included within the definition of condensed milk and it can be exempted from

levying tax.

APPRAISAL OF PRINCIPLE

It may be paradoxical that plain meaning rule is not plain and requires no construction, starts

with a premise that the words are plain, which is itself a conclusion reaches after construing the
11
(2013) 5 SCC 277 p.331

10 | P a g e
words12. The rule, that plain words require no construction, starts with the premise that the words

are plain, which is itself a conclusion reached after construing the words. It is not possible to

decide whether certain words are plain or ambiguous unless they are studied in their context and

construed13. The rule therefore, in reality means that after you have construed the words and

have come to the conclusion that they can bear only one meaning, your duty is to give effect to

that meaning. For a proper application of the rule to a given statute, it is necessary, therefore, to

determine first whether the language used is plain or ambiguous. As pointed out by Lord

Buckmaster, “by any ‘ambiguity’ is meant a phrase fairly and equally open to diverse meanings”.

PRESENT POSITION IN INDIA

Let’s take the case of Kanai Lal v.Paramnidh.14 This case basically dealt with the ejection

of thika tenants under provisions of Calcutta Thika Tenancy Act, 1949. The court said “It must

always be kept 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 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 construction15.”

In S.A.Venkataraman v. The State16, the court said. This case dealt with Section 6 of the

Prevention of Corruption Act. It was to do with taking a sanction from an appropriate authority.

12
SINGH, supra note 3
13
D. Saibaba v. Bar Council of India and Anr AIR 2003 SC 2502
14
A.I.R 1957 SC 907.
15
4Justice G.P SINGH, PRINCIPLES OF STATUTORY INTERPRETATION 53(11th ed 2008)
16
A.I.R 1958 SC 107

11 | P a g e
It considers only the present working employees as employees; those who have retired are not

considered as employees. The court said, “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”. Apparently clear and simple language at times in its analysis is so

ambiguous as to present great difficulty in construction .regarding Article 105(2) of the

Constitution which provides 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 in Tej Kiran Jain v. N.Sanjeeva Reddy17 held that the Article means

what it says in language which could not be plainer. In the case of P.V Narshima Rao v.

State(Central Bureau of Investigation)18 when Mr.P.V.Narshima Rao was the Prime Minister, the

government faced a no-confidence movement, which was defeated later on. However they were

few members who were accused of the offence of giving and taking bribes and the President of

Rashtriya Mukti Morcha filed a complaint, against the P.V.Narishma Rao, alleging charges of

corruption, with the Central Bureau of Investigation. However Article 105 of the Indian

Constitution which gives provisions for the powers and privileges of the members of the House

of Parliament. It was held by a majority of three judges that a member who voted in Parliament

after receipt of bribe cannot be prosecuted as his prosecution would be a proceeding in respect of

a vote given by him and barred by Article 105(2).

In another case Ramavtar Budhaiprasad v. Assistant Sales Tax Officer19, the Supreme

court was faced with a question with the meaning of “vegetable”, as it had occurred in the C.P

and Berar Sales Tax Act, 1947 as amended by Act of 1948,whether the word vegetables included

17
(1971) 1 SCR 612.
18
(1998) 4 SCC 626
19
(1961) A.I.R SC 1325

12 | P a g e
betel leaves or not. The Supreme Court held that “being a word of everyday use it must be

construed in its popular sense20”. It was therefore held that betel leaves were excluded from its

purview.

In the case of Forest range Officer v. Khushboo Enterprise21 The question in the case was

whether sandal wood oil is “wood oil” as used in the Section 2(f) of the Kerala Forest Act, 1961.

The argument referred to a technical dictionary which defined wood-oil as a natural produce of

the forest. Hence it was held that sandalwood oil was a wood-oil. In the case of Vemma Reddy

Kumarsawmy Reddy v. State of Andhra Pradesh22, The dispute was regarding the excess of land

possessed by the appellant, and this was surrendered by them, however it had cashew-nut

plantation. The trees in the surrendered land were fruit bearing. The court stated that in

construing if it was plain and ambiguous then the primary rule of interpretation was supposed to

be used.

MERITS

The advantages while using literal rule of interpretation. Literal rule of interpretation being a

traditional rule of interpretation is often advocated by jurists of the plain meaning rule who claim

that it prevents courts from taking sides in legislative or political issues. They also point out that

ordinary people and lawyers do not have extensive access to secondary sources23 . It is also

argued, that extrinsic evidence should not be allowed to vary the words used by the testator or

their meaning. It can help to provide for consistency in interpretation.

20
TRIPATHI, supra note 40, at 127.
21
A.I.R 1994 SC 120
22
(2006) 2 SCC 670
23
SINGH, supra note 3

13 | P a g e
JURISTIC ANALYSIS

CASE STUDIES

a. Kanai Lal v. Paramnidh24

The court said-“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 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 basically dealt with the ejection of ‘theka’

tenants under provisions of Calcutta Theka Tenancy Act, 1949.

b. S.A.Venkataraman v. The State25

The court said that this case dealt with Section 6 of the Prevention of Corruption Act. It was to

do with taking a sanction from an appropriate authority .It considers only the present working

employees as employees, those who have retired are not considered as employees. The court

said, “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.”

c. Ramavtar Budhaiprasad v. Assistant Sales Tax Officer26 The Supreme court was faced

with a question with the meaning of “vegetable”, as it had occurred in the C.P and Berar Sales

Tax Act, 1947 as amended by Act of 1948,whether the word vegetables included betel leaves or

24
AIR 1957 SC 907
25
AIR 1958 SC 107
26
AIR 2002 SC 135

14 | P a g e
not. The Supreme Court held that “being a word of everyday use it must be construed in its

popular sense”27. It was therefore held that betel leaves were excluded from its purview.

d. Harbhajan Singh v. Press Council of India28 Sub- section 7 of section 6 of the Press Coucil

Act, 1978 provides: ‘A retiring member shall be eligible for renomination for not more than one

term.’ The Supreme Court applied the literal and grammatical meaning of these words and held

that the provision applied to a member “just retiring” and not to a retired member and that a

retired member who had held office for two terms sometime in the past is not debarred from

being nominated again.

CHAPTER III

CRITICISMS OF THE LITERAL RULE OF INTERPRETATION

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 “syntactic29” 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

27
Ramavtar Budhaiprasad v. Assistant Sales Tax Officer A.I.R 1961 SC 1325; p.1326
28
AIR 2002 SC 1351
29
P J FITZGERALD,,SALMOND ON JURISPRUDENCE 152 (12 th ed.,Universal Law Publishing
Co.Pvt.Ltd.,2008).

15 | P a g e
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 injustice30. 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 sense31.

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.

 AMBIGUITY

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

30
CIT vs. T.V. Sundaram Iyyengar [1975] 101 ITR 764 (SC)
31
AIYER,P.RAMNATHAN, LAW LEXICON 1134 (2 nd ed.,Wadhwa and Co., ,2002).

16 | P a g e
 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

 INCOMPLETENESS

It means that there is some lacuna or omission in the statute which prevents it from giving a

complete idea, or it is logically incomplete. In such cases 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.

 ABSURDITY

Sometimes the court might ascertain a certain meaning to the statute which was never the

intention of the legislature. This is also one of the problems of literal rule.

 RESTRICTION ON COURTS

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.

 NOT SUITABLE FOR CHANGING TIMES

With a change in policies and legislation, the statutes cannot still be interpreted in accordance

with the ordinary meaning of the words made long ago32.

32
N.S BINDRA, INTERPRETATION OF STATUTES 4 (9 edn Lexis Nexis Butterworths, 2002).

17 | P a g e
 CHAPTER IV

There are other rules of interpretations of statutes such as

 Golden Rule of Interpretation

 The Mischief Rule

 Rule of Harmonious Construction

 Rule of Beneficial Construction:

Golden Rule of Interpretation

The Golden rule, or British rule, is a form of statutory interpretation that allows a judge to depart

from a word's normal meaning in order to avoid an absurd result.

It is a compromise between the plain meaning (or literal) rule and the mischief rule. Like the

plain meaning rule, it gives the words of a statute their plain, ordinary meaning33. However,

when this may lead to an irrational result that is unlikely to be the legislature's intention, the

judge can depart from this meaning.

The Mischief Rule

The mischief rule is a certain rule that judges can apply in statutory interpretation in order to

discover Parliament's intention. Originating from a 16th century case (Heydon’s case) in the

33
Rao Mn & Dhanda Amita, Bindra N S, INTERPRETATION OF STATUTES 433(10 th edn Lexis Nexis
Butterworth’s, 2007

18 | P a g e
United Kingdom, its main aim is to determine the "mischief and defect" that the statute in

question has set out to remedy, and what ruling would effectively implement this remedy

Rule of Harmonious Construction

When there is a conflict between two or more statues or two or more parts of a statute then the

rule of harmonious construction needs to be adopted. The rule follows a very simple premise that

every statute has a purpose and intent as per law and should be read as a whole34. The

interpretation consistent of all the provisions of the statute should be adopted. In the case in

which it shall be impossible to harmonize both the provisions, the court’s decision regarding the

provision shall prevail.

Rule of Beneficial Construction:

Beneficial Construction is a tendency and not a rule. The reason is that this principle is based on

human tendency to be fair, accommodating, and just. Instead of restricting the people from

getting the benefit of the statute, Court tends to include as many classes as it can while remaining

faithful to the wordings of the statute.

For example, in the case of Alembic Chemical Works vs. Workmen35, an industrial tribunal

awarded more number of paid leaves to the workers than what Section 79(1) of Factories Act

recommended. This was challenged by the appellant. The Supreme Court held that the enactment

being welfare legislation for the workers had to be beneficially constructed in the favour of

34
https://indconlawphil.wordpress.com/tag/harmonious-construction/
35
AIR 1961

19 | P a g e
worker and thus, if the words are capable of two meanings, the one that gives benefit to the

workers must be used36.

The golden rule is a slight modification of the Literal Rule. It is considered a part of the literal

construction.

In this case the court can depart from the ordinary meaning of the words; here it tends to avoid

absurdity. Mischief rule is to remove the mischief in a statute. Literal rule is the most ancient

rule used in interpretation. Where there is an inconsistency, the judiciary will attempt to provide

a harmonious interpretation.

CHAPTER V

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 India37. 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

36
Rao Mn & Dhanda Amita, Bindra N S, INTERPRETATION OF STATUTES 433(10 th edn Lexis Nexis
Butterworth’s, 2007
37
Bindra N.S, Interpretation Of Statutes (9 edn Lexis Nexis Butterworth’s, 2002).

20 | P a g e
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.

21 | P a g e
BIBLIOGRAPHY:

Books referred:

 Bindra N.S, Interpretation Of Statutes (9 edn Lexis Nexis Butterworth’s, 2002).

 Chipman John, Gray Nature And Sources Of Law, 176(2 nd Edn.) The Columbia University

Press.

 Fitzgerald P J,Salmond On Jurisprudence 152 (12 Th Ed,Universal Law Publishing

Co.Pvt.Ltd.,2008).

 Aiyer, P.Ramnathan, Law Lexicon 1134 (2 Nd Ed,Wadhwa And Co., ,2002).

 Deepak Jain, INTERPRETATION OF STATUTES: A TREATISE

 Rao Mn & Dhanda Amita, Bindra N S, INTERPRETATION OF STATUTES 433(10

th edn Lexis Nexis Butterworth’s, 2007.

 BLACKS LAW DICTIONARY 1084(17 TH Ed.).

 .St.Langan J. ,Maxwell INTERPRETATION OF STATUTES 306(12 Th Ed,Lexis

Butterworth’s).

Sites referred:

 http://www.caaa.in/Image/Interpretation%20of%20Statutes.pdf

 http://hanumant.com/index.php/academics/law-notes/14-interpretation-of-

statutes.html

 http://lawtimesjournal.in/interpretation-of-statutes-important-questions

 https://definitions.uslegal.com/l/literal-rule/

 https://kively2010.wordpress.com/2011/12/20/what-are-the-difference-between-

literal-golden-and-mischief-rule/

22 | P a g e
  https://www.translegal.com/lesson/statutory-interpretation-2

 https://www.stuvia.com/doc/55829/explain-the-literal-rule-of-statutory-

interpretation

 https://www.lawctopus.com/academike/mischief-rule-statutory-interpretation/

Articles referred:

 Daniel Ashley, LITERAL RULE OF STATUTORY INTERPRETATION,

Winstanley College, UK. 2012

 Rao Subhyanka, RULE OF STATUTORY INTERPRETATION, RMLNLU 2014

 Rajkumar C A, INTERPRETATION OF STATUTES, CAAA.in

23 | P a g e
24 | P a g e