The Role of the Golden Rule in Statutory Interpretation

“By Interpretation or construction is meant the process by which courts seek to ascertain the meaning of the Legislature through the medium of authoritative forms in which it is expressed.” -Salmond

Statutory Interpretation is the process of interpreting and applying legislation to decide cases. Interpretation becomes essential when a legal case presents intricate or unclear elements within a statute. While statutes usually have a clear and straightforward meaning, instances may arise where the statute’s wording is ambiguous or imprecise, necessitating resolution by the judge.

The primary aim of statutory interpretation is to discern the intent of the legislature, whether that intent is explicitly stated or implied through the language employed.

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; that is the sense that their author intended to convey; and of enabling others to derive from them the same idea which the author intended to convey.

In the case of RMD Chamarbaugwala v. UOI (1957), it is firmly established that statutes must be construed in alignment with the intent of those who enact them. The judiciary has a pivotal role in discerning and acting upon the true intention of the legislature, a concept known as Mens or Sententia Legis. Justice Gajendragadkar reinforces this principle by asserting that the primary rule of construction is to extract the legislative intent from the actual words chosen by the legislature.

The Golden Rule carries substantial significance within the realm of legal interpretation. It places an obligation on the Court to uphold the intended purpose of law when adhering strictly to a literal interpretation would result in absurdity or defeat the legislative objective. In such instances, the Court may find it necessary to make adjustments to the grammatical and everyday sense of the language used in the statute.

The Golden Rule in interpretation goes beyond the Literal Rule, granting judges the authority to depart from a stringent, word-for-word interpretation to avert unreasonable results. Under the Golden Rule, when construing a statute, the Court is typically expected to adhere to the everyday sense of the words utilized. The approach involves modifying the language and grammar of words used in statutes and other interpretive documents to arrive at the actual intended meaning.

In 1857, Lord Wensleydale introduced the golden rule of interpretation in the case of Grey v. Pearson. Since then, this rule has become well-known as Wensleydale’s golden rule. Maxwell’s perspective underscores the default principle that words in a statute should be given their ordinary meaning. This approach represents a modification of the strict principle of literal or grammatical interpretation. Courts employ the Golden Rule of interpretation in pursuit of a precise interpretation that reveals the true meaning of the language used, ensuring that the genuine intention of the legislature is effectively realized.

The Golden Rule can be applied in both a narrow and a wider sense:

• The narrow approach to interpretation is employed when a word in a statute has multiple meanings, allowing judges to choose the most appropriate meaning for the specific case.
• The wide approach is used when there is only one literal meaning of a word, but adhering to it would result in an absurd outcome, permitting the court to modify the interpretation to avoid absurdity.

SIGNIFICANCE

The purpose of invoking the golden rule is to avoid the rigour of literal rule when its application results in absurdity/inconsistency. Although the rule permits the plain meaning rule to be departed from, if a strict adherence to it would result in an absurdity but the later part of the golden rule must be applied with much caution.

The Apex Court in Jugal Kishore v. Raw Cotton Co. Ltd. (1995) laid down that the cardinal rule of interpretation is to read the statute literally. If such a reading leads to an absurdity and the words are susceptible of another meaning the court may adopt the same.

The golden rule is of great significance in the field of interpretation of statutes. It levies a duty upon the court to give effect to the intended meaning of the law when following the literal interpretation would lead to absurdity or defeat the purpose of the enactment. The key objectives of the golden rule are:

• Avoiding Absurdity: The golden rule ensures that the court can prevent absurd or illogical outcomes by departing from a strict literal interpretation when necessary.
• Preserving Legislative Intent: It upholds the duty of the Court to give effect to the intended meaning of a law, safeguarding the purpose behind the legislation.
• Balancing Literal Interpretation: While departing from a literal interpretation, it strikes a balance by allowing the Court to modify the grammatical and ordinary meanings of words when essential.
• Equitable Application: By allowing for interpretation that aligns with common sense and justice, it ensures a more predictable and equitable application of the law.
• Consistency: When words within the law are not absurd or ambiguous, interpreting them based on their natural and customary meaning promotes consistency and maintains the legislative intent.
• Clarity and Reasonability: It mandates that the court should not deviate from the law’s plain and intelligible meaning unless it is practically impossible to derive the intended meaning from the text.

APPLICATION OF THE GOLDEN RULE

The application of the golden rule in legal interpretation is contingent upon the consequences that may arise from its use. When the circumstances necessitate the use of the Golden Rule, it becomes crucial to consider the potential effects and consequences that would emanate from its application. This consideration is vital for the purpose of elucidating the genuine meaning of the words in question. In essence, the golden rule is employed with a keen awareness of the possible outcomes it may yield in order to discern and uphold the true intent behind the words used in a statute.

In Mattison v. Hart (1854), recourse was taken of the golden rule as applied to the Acts of Parliament, viz.; to give to the Words Used by the Legislature their plain & natural meaning unless it is clear from the general scope & Intention of the statute. Injustice and Absurdity would result from so construing them.

In the case of State of Punjab v. Qaiser Jehan Begum (1963), the apex court ruled that the parties to apply for reference under section 18 of the Land Acquisition Act of 1894, they must first be aware of the award. Since the parties were not informed of the award through notice, the limitation period from the date of receiving notice of the award.

The Supreme Court applied the golden rule of interpretation to conclude the age determination of one of the appellants in the case of Ramji Missar v. State of Bihar (1962). The court ruled that the younger brother’s age was under 21 years at the time of the offence, making him eligible for the benefits under section 6 of the Probation of Offenders Act, 1958 stating that the age determination for section 6 should be based on the date of the guilty verdict rather than the date of the offence.

In Lee v. Knap (1967), the interpretation of the word ‘stop’ was involved. Under section 77(1) of the road traffic Act, 1960 a driver causing an accident shall stop after the accident. In this case, the driver stopped for a moment after causing an accident and then moved away. Applying the golden rule the Court held that requirement of the section had not been followed by the driver as he had not stopped for a reasonable period of time requiring interested persons to make necessary inquiries for him about the accident.
 

ADVANTAGES

• Offers the court flexibility to select the most sensible interpretation when words in an Act or Statute have multiple meanings.
• Provides an alternative approach when strict literal interpretation poses issues.
• Allows for reasonable decisions in cases where the Literal rule would in result in repugnant outcomes, such as illustrated in the Re Sigsworth case.
• Generally respects parliamentary language with exceptions in limited circumstances.
• Empowers judges to potentially influence legal interpretations and change the meaning of words in statutes, although this must be done within the bounds of the separation of powers.
• Facilitates the prompt correction of drafting errors in statutes, ensuring alignment with parliament’s intentions and delivering fairer outcomes, as exemplified in the R v Allen case (1872).
   

DISADVANTAGES

• Lack of clear guidelines for determining when it can be applied.
• Highly restricted in its application, leading to infrequent use.
• Unpredictability in the Court’s decisions regarding the use of the Golden Rule, creating challenges for lawyers and advisors.
• Subjectivity in interpreting what constitutes absurdity may vary among judges, leading to case outcomes influenced by judicial discretion rather than a clear legal standard.
• Ineffective in cases where no absurdity is present in the statute, as held in the case of the London and North Eastern Railway v. Berriman case, where compensation for a widow was not feasible due to the statute’s wording limitations.

CONCLUSION

In conclusion, statutory interpretation aims to uphold the rule of law by balancing the need for unambiguous language with the necessity for flexibility in cases where rigid adherence to literal interpretation would lead to unjust or impractical results. The Golden Rule provides a valuable tool for achieving this balance, allowing the law to be applied in a manner that respects both the language of the statute and the broader goals of justice and equity.