This Article is written by Tanvi Sondkar, a Third-Year Law Student of Advocate Balasaheb Apte College of Law

To determine the meaning of laws and other legal rules, the judiciary employs the interpretation process. In a broader sense, it is the process by which a court looks for the true intention of the legislator behind a legislative provision and strives to determine the true meaning of a word, phrase, or expression that is in question in any statute that is before the court. To determine the meaning of laws and other legal rules, the judiciary employs the interpretation process. Generally speaking, it refers to the process by which a court looks for the real meaning of a word, phrase, or expression that is disputed in any statute that is before the court and determines the legislative intent behind such a legislative provision. When it comes to statutory interpretation, the judiciary can use a variety of tools and principles. These include applying primary or secondary rules of interpretation that the court has developed over time, as well as seeking assistance from internal or external resources.

Internal Aids.

Titles of Statutes.

Statute titles are crucial for giving references and a broad understanding of the legislation’s intent. There are two types of titles:

Short Title

An Act's brief title acts as a succinct designation for the legislation, making it simple to find and refer to. It also includes the year in which the Act is passed. The Indian Contract Act, for instance, specifies in Section 1 that "This Act may be called the Indian Contract Act, 1872." The Indian Relations Code, also states in section 1 that “This Act may be called the Industrial Relations Code, 2020. The short title is usually accompanied by extent and commencement of the statute.

Long Title

Not all but some acts may have a long title that gives you a general summary of the legislation's goal or purpose. It provides an outline of the Act's intended use and scope. It is necessary, therefore, that the lengthy title is not regarded as a definitive tool for statutory interpretation.
Instead of providing a clear knowledge of the subject matter of the Act, it does not clarify any misunderstandings that may occur within the statutory requirements.

For example, the Code of Civil Procedure (CPC) is titled "An act to consolidate and amend the laws relating to the procedure of the courts of civil judicature," according to its lengthy title.
Although the lengthy title gives an overview of the Act's goals, it shouldn't be the exclusive source of interpretation when other internal resources and particular clauses are available.

Preamble

An Act's preamble provides an internal help to interpretation by outlining the primary goals and motivations for the legislation. The preamble usually has little bearing when a provision of an Act is expressed in plain and unambiguous language. Still, the preamble can help determine the real meaning of the law in cases when there are conflicting interpretations. Although it is important to note that many contemporary acts are written without a preface, which lessens their significance, the preamble is normally found on the opening page of the Act.

In case, State of West Bengal v. Anwar Ali, the whole of validity of Section 5 of the West Bengal Special Courts Act, 1950 was contested, on the grounds that it violated Article 14 of the Constitution. This clause allowed the state government to designate particular cases for unique courts with unique trials. The state government had the authority to select such cases, the Supreme Court held, citing the preamble of the Act.

Marginal Notes

Marginal notes are inserted at the side of the sections in an act which express the effect of the section but they are not part of statute. Although they are not a part of the statute, they articulate the intent of the section. Marginal notes are typically inserted by drafters rather than legislators. In the past, when it was unclear what a provision clearly meant, marginal remarks were occasionally taken into consideration for interpretation. Nonetheless, because legislators do not add marginal notes or include them in the statute itself, the present legal perspective holds that they have no bearing. The constituent assembly does, however, create marginal notes, which are sometimes cited when interpreting the constitution.

The Supreme Court ruled in the case of Bengal Immunity Company v. State of Bihar that the Indian Constitution includes the marginal notes of Article 286—which deal with limitations on the application of taxes on the sale or purchase of commodities. As a result, one could rely on them to shed light on the meaning and goal of the piece.

While marginal notes may have limited significance in the interpretation of statutes, they can still offer valuable context in interpreting constitutional provisions.

Headings

Sections or groupings of sections in a statute have headings appended to them. The accompanying section or sections' preambles have been interpreted by courts. The plain language of the provision cannot be controlled by headings, it is crucial to remember that. Headings are internal tools that help with interpreting statutes.
They only play a part in situations where there are multiple possible interpretations based on how the section is understood plainly. In such cases, the court may look to the headers for direction in order to ascertain the legislative intent.
The Road Traffic Act's Section 217 was interpreted differently in the case of Tolley v. Giddings. Penalization of seizing a motor vehicle was the subheading under the title "Miscellaneous and general" of the regulation.

Illustrations:

Sections of statutes are accompanied by illustrations, which serve as instances of the laws described in the provision. They serve as a manifestation of the legislative intent and are consultable in repugnancy or ambiguity situations. Nonetheless, it is emphasized by a number of rulings that the illustrations do not fully clarify the principle covered in this section or set its boundaries. The section will take precedence over an illustration in the event of a dispute.

For instance, in the Indian Penal Code (IPC), Section 378 has 16 illustrations.

Explanations

Statutes contain explanations to help make a particular provision more understandable and to dispel any questions that would have arisen if the explanation hadn't been included. The aim of explanations is to elucidate the meaning and intention of the Act, remove any ambiguities or obscurities, and offer further evidence in favour of the Act's goal. Because of this, explanations also function as internal tools for interpreting statutes.

For example, Section 108 of the IPC defines the word “abettor,” which has five explanations attached.

Definition or Interpretation Clause

Legislation often includes definition or interpretation provisions that provide additional meaning to words that are used frequently, thereby reducing the need for repeating descriptions and preserving the original meaning of the words as intended by the statute. In addition to preventing confusion, these provisions make clear the legislature's intentions about the usage of particular words in the act.
Definition clause interpretation guidelines provide that if the terms "means" or "means and includes" are used, the definition is exhaustive and does not permit a more expansive reading. Nonetheless, when the term "includes" is employed, it offers the most expansive interpretation or expands the word's typical meaning.

Nonetheless, the court will not apply such criteria if doing so would produce an irrational outcome. A statute's definition clause cannot also be used to define a word that appears in another legislation, with the exception of statutes that deal with related themes or Pari Materia.

The meaning of the term "tobacco" was under dispute in the Mahalaxmi Oils Mills v. State of A.P. case. Tobacco is defined as any tobacco, produced or unmanufactured, as well as the leaves, stalks, and stems of the tobacco plant. Rejecting the inclusion of tobacco seeds in the definition of tobacco, the Supreme Court ruled that the term was comprehensive.

Punctuation

A variety of symbols, including full stops, dashes, hyphens, brackets, colons, semicolons, and commas, are used to denote statue punctuation. Statutes were not punctuated when they were passed in the past, therefore courts had to give them additional weight. Nevertheless, statutes are passed punctually in the present era.
The rule of interpretation for punctuated provisions states that the court should read the law as a whole and not give the punctuation any weight if it finds itself faced with repugnancy or uncertainty. It should be regarded appropriately if the message is obvious.

Schedules

The final sections of legislation are called schedules, which identify topics, provide further information, and specify forms. In the event that the major body of an act and the timetable clash, the main body takes precedence. As a result, schedules support interpretation internally.
In Schedule 1, for instance, the states' names and their respective territories are listed, and Article 1 of the constitution declares that India would be a union of states.

Saving Clauses

When a statute is repealed and then re-enacted, saving provisions are usually added. To prevent the creation of new rights or the disruption of rights already established under the repealed law, they are placed into the repealing statute. A statute's saving clause is disregarded if it conflicts with the main body of the law.

Provisos

A proviso is an internal tool for statutory interpretation and is deemed to be part of the section. It is intended to qualify or exempt specific provisions, establish necessary requirements for the legislation to be feasible, function as optional addenda, or integrate into the enactment itself. Provisos cannot be interpreted to negate the effects of the main enactment or to broaden its scope. Only in cases of ambiguity within the provision may provisos be referred to. In the event that a proviso and the main enactment disagree, they must be interpreted harmoniously. However, other legal scholars contend that because the proviso expresses the legislature's most recent intent, it is superior.
Article 16(4) of the Constitution of India is considered a proviso to Article 16(1) as held in T. Devadasan V. Union of India.

Exceptions

Statutes contain exceptions to exclude from the main provision some things that would otherwise fall under its purview. If there is a disagreement between the main enactment and an exception, the latter should be relied upon. Exceptions, on the other hand, are frequently regarded as the legislature's final intention and can help interpret regulations.
For instance, Section 300 of the IPC is subject to five exclusions.

External Aids:

Punctuation, schedules, saving clauses, provisos, and exclusions must all be taken into account when interpreting statutes in order to ascertain the legislative intent and give the law effect.

Dictionaries

The court may use the legislation's dictionary definition to determine the meaning of a word used in the statute when it is not specified therein or, if it is, only in certain circumstances. Such terms must be examined to ensure that they are discussing the specific statute, as words can have varied meanings depending on the context.
The issue in Motipur Zamindary Company Private Limited v. State of Bihar [10] was whether sugarcane might be subject to sales tax.

The petitioner claimed that as it is a green vegetable, taxation should not apply. Vegetable, according to the dictionary, refers to anything developed or obtained from plants. The SC disagreed with the dictionary definition, ruling that sugarcane is not a vegetable and that a vegetable is generally something that is cultivated in a kitchen garden and eaten at lunch and supper

Text Books

When interpreting a statute, the court may consult standard textbooks to clarify its interpretation. However, the courts are not required to agree with this viewpoint.

The court time and again referred to Kautiliya, Manu, Arthshastra.

Example: in Kesavananda Bharthi case [11], judges quoted large number of books.

Statement of objects and reasons

The bill has an accompanying statement of object and reasons that explains the purpose, goals, and rationale of the measure. It also provides insight into the history, the pre-existing conditions, and the goal of the legislation.
A bill's intended purpose must be taken into account by the parliament before it is passed. But because it fails to convey the actual meaning of the statutory provision, it is not regarded as a definitive help to interpretation.

Constituent Debates/Speech

All of the debates that occurred in the parliament during the drafting of the Indian Constitution will be compromised by it. In the event that the Constitution is found to be inconsistent or repugnant, the court may openly cite these discussions.

The court considered the meaning of the phrase "backward class of citizen" as used in Article 16(4) in the case of Indra Sawhney v. Union of India [12]. To appreciate the context, history, and purpose of the use of the stated expression, the SC in this instance referred to the address made by B.R. Ambedkar.

Legislative Debates/Speech

It refers to the speeches or debates that member of the parliament hold to express their opinions while a law is being passed. Since speeches are frequently influenced by political pressure or may be inaccurate to rely upon, they are not regarded as definitive aids to interpretation and are, thus, not acceptable.

Committee Reports

Typically, a committee is tasked with thoroughly reviewing the topic and providing a report before the bill is framed.
These commission and committee reports have been cited as supporting documentation for historical facts or contextual information for interpreting the Act.
Help can be obtained from the committee report to interpret a provision where there is uncertainty about its meaning and the act was approved based on its suggestion.

An illustration of this would be the criminal amendment act, which was based on the J.S. Verma Committee Report's proposal. If there is any uncertainty in the amendment, this report should be consulted.

Foreign laws and decisions

If the political systems and ideologies of the two nations are comparable, if there is no domestic legislation relevant to the issue, and if the Indian court believes that the decision made by the foreign court is not arbitrary, judges may refer to foreign laws and decisions. The Indian courts are not bound by the rulings of international courts; hence the foreign courts' rulings merely have persuasive value.

Example: in Right to Privacy case, judges refer to foreign judgements.

Conclusion

Internal aids to interpretation of statutes include examining titles, preambles, headings, illustrations, explanations or definition clauses; internal aids offer insights into the context, scope and application of statutory provisions.[1]

1. https://blog.ipleaders.in/rules-interpretation-statutes/

2. https://indiankanoon.org/search/?formInput=interpretation%20of%20statute

3. https://www.slideshare.net/slideshow/interpretation-of-statues-meaning-object-types/266707165

4. https://www.lexisnexis.in/blogs/interpretation-of-statutes/

5. https://www.yalelawjournal.org/forum/googling-for-meaning-statutory-interpretation-in-the-digital-age