INTRODUCTION
In India, the justice system is vital in certifying that society is treated fairly and justly. Its activities have a range of effects on people. For this motive, only those with the necessary intelligence and expertise are selected to serve as court judges. On rare occasions, the execution of ambiguous language by the lawmaker makes the plan less evident, so someone has to fix this error. The principles of interpretation originated by a few geniuses to help the judges discern whether a term needs to be read alternatively and precisely what that interpretation ought to be.
The literal principle of interpretation was lately tailored and is now the golden rule. The golden rule examines words in a way that avoids illogicality and irregularities of literal interpretation, although the literal rule concentrates on the words’ literal meaning when employed in legal language. The golden rule lends words real significance by modifying their language and grammar when they originate in law among other interpretation papers.
MEANING
The “Golden Rule” of Interpretation is an essential doctrine that guides the interpretation of legal material, outlining the relevance of justice, fairness, and reasonableness in legal decisions. Originating in ancient civilizations and faith traditions, it portrays the moral precepts upheld by religious leaders like Jesus Christ and intellects like Confucius. Attorneys use this tactic in jury trials to ask judges to see themselves as the victim or damaged party and declare the result they would have preferred if they were in that person’s shoes.
The literal doctrine is expanded upon or stretched by the golden principle of interpretation, and this facilitates judges to wander from the literal meaning of statements to avoid ludicrous ramifications. The golden rule states that the Court must typically follow the terms’ usual interpretation when interpreting a statute.
In Becke versus Smith, Parke B articulated the well-known rule for statutory interpretation in a manner that even if the exact words utilized lead to an irrationality or obvious unfairness in their interpretation, people are obligated to interpret them in their common sense if their meanings are unambiguous. Words might get tweaked or altered when their meaning is unclear or questionable, but when we divert from the exact meaning of the words used because we reckon, they are outrageous or unfair when taken, we serve as legislators.
GOLDEN RULE’S BEGINNINGS
The principle of the golden rule in interpretation had originally been put forward by Lord Wesleyan in Grey versus Pearson. In 1857. Over then, this rule has gained prestige as Wensleydale’s Golden Rule. The court adheres to the words’ common meaning and grammatical structure. The court has the authority to interpret a statute if its wording is imprecise.
The golden rule applies if there is ambiguity, difficulty, unfairness, inequity, difficulties, or annoyance. The “golden rule” could be implemented if the court’s literal rule is illogical.
The Golden Rule’s method
- Narrow method: This method is used when a statute’s language can be interpreted in an assortment of ways. The court can apply a clear interpretation that precisely conveys the statute’s genuine intent by using this method. The case of R v. Allen (1872) employed this method. The task assigned to the court in this case was to interpret a law that outlawed “marrying a partner of the lifeless.” The defendant asserted that the marriage was outside the statute’s ambit because it took place after the spouse’s burial. The court yet upheld the legislative objective and strengthened the fundamental values of justice and fairness by applying the notion of the Golden Rule in solving the confusion and reading Act to embrace marriages consummated to circumvent the law’s prohibition.
- Broad method: This method is used when a word may possess only one single meaning. In certain situations, the meaning may lead to nonsense. To avoid this issue, judges can employ this method to change the meaning of a term, but they have to apply it wisely and without breaking from the legislation’s true ambition. The case of Re. Sigsworth: Bedford versus Bedford (1954) employed this method.
Case law outside India
- In the Vacher and Sons versus London Society of Compositors Case (1912), Lord Moulton noted the worth of exercising caution before using the ” golden rule ” of interpretation. As per him, there is a risk that the typical scenario will only result in judge scrutiny of the validity of laws. We need to interpret the law based on their wording. By reviewing Act overall and evaluating it in light of the state statute that was in effect at that period, we may be convinced that the terminology deployed is inapplicable to the clashing interpretation, nevertheless, the outcome of the two opposing interpretations could aid us to decide.
The court used this case to assess the wording of the Act and consider conflicting interpretations to reach a decision.
- In 1967, Lee versus Knapp ‘Stop’ had been interpreted differently in this specific case. A driver who commits an accident is required to stop following the collision by section 77(1) of the Road Safety Act of 1960. In the present scenario, after experiencing an accident, the driver merely stopped before continuing on his path. Using the notion of the golden rule, the trial judge identified that the driver had not complied with the section’s criteria since he did not stop for an appropriate period. Requiring any with curiosity in the accident to ask him the questions they have to.
The judiciary was able to determine whether or not the clause was correctly followed owing to this case. Enthusiasm prompted inquiries when the trial judge applied the “golden rule” in deciding that the driver had not stopped for an appropriate duration of time.
- The Free Lanka Insurance Company, Limited versus Ranasinghe Escaping out of detention is considered an offence. Since the lockup was burning, a prisoner succeeded in escaping. According to the court, the inmate’s jailbreak retrieved his life. A statute that categorically declared “an act” illegal was perceived as not applying in scenarios where the act was justified or permissible for legitimate reasons.
- According to Lord Blackburn’s comment in Rivers Wear Commissioner versus Adamson, the judge must perpetually interpret a term in a way that discloses its usual meaning.
This ruling implied that judges should consider any act according to the term’s ordinary meaning.
Case Law in India
- In the Golaknath Case, the nation’s highest court utilized the Golden Rule of Interpretation and presided that Parliament was prohibited from amending the constitution in a way that could impact the provisions under part three (Fundamental Rights).
- In the dispute of the State Bank India versus Shree N. Sundara Money, the highest court in the country ruled that the freedoms of the public should be given precedence over individual liberties. Further, according to the golden rule of interpreting, a law’s terminology should be rejected if it is discriminatory in a specific case.
- The meaning of the statement “by a person” about the second clause of section 2 of the Act governing industrial disputes was important in the Dimakuchi State versus Management Case. The act’s purpose and plan made it clear that “any person” meant those who had an obvious and significant stake in the economy. Under the Law on Industrial Disputes, a visitor or stranger could not be regarded as “any person.”
- Based on the Indian Supreme Court’s ruling about the UP Bhoodan Yagna Samiti vs Brij’s Kishore Case, only “landless labourers” constituted “landless persons” under the fourteenth section contained in the “U.P. Bhoodan Yagna Act of 1953,” which made it possible to provide land to those residing without it. Labourers who perform on farms but do not own farmland constitute landless labourers.
- In the government of Mysore State vs Sundaram Motors Private Limited. Scenario there was ambiguity due to the legal meaning of the phrase “motors vehicle kept inside the state” under Section 3(1) of the Mysore Vehicles Act. This expression was first used to describe transportation that utilized all of its advantages provided by the territory of Mysore.
- By declaring Clause 254(2-A) from the Finance Act 1999, unlawful within Article 14 for equal treatment, the Supreme Court’s historic ruling in CIT vs. Pepsi Foods Ltd. Upholds the principles of the Golden Rule from interpreting and guarantees equitable tax appeal procedures.
CONCLUSION
If the Statute’s phraseology is normal, plain, and clear, then that should be its meaning. It is vital to interpret statutes in a way that makes the legislature’s intent visible. Such an interpretation is to be eschewed since it correlates directly to injustices. Interpretations that are illogical and meaningless ought to never be approved. The phraseology of the statute may be changed, and alternative rules of interpretation may be applied, if it is unidentified, gives rise to several interpretations, or does not convey the legislature’s intent. The Golden Rule in Interpretation is such.
Author(s) Name: Rishabh Krishan (Amity University Jharkhand)
