CHANAKYA NATIONAL LAW UNIVERSITY

PATNA

Project Title in Interpretation of Statute and Principles of Legislation (Final Draft)

====================================================

Purposive Construction
=======================

Submitted to:
Dr. Ali Mohammad
Faculty of ISPL
Prepared by:
Rajeev Ranjan
Roll No. – 1360, Semester VII
 ACKNOWLEDGEMENT
I would like to thank my faculty Ali Sir whose guidance helped me a lot with structuring my
project.
I owe the present accomplishment of my project to my friends, who helped me immensely with
materials throughout the project and without whom I couldn’t have completed it in the present
way.
I would also like to extend my gratitude to my parents and all those unseen hands who helped me
out at every stage of my project.
I would especially like to thank my roommate Shubham Priyadarshi whose technical assistance
is unforgettable.
THANK YOU,
RAJEEV RANJAN

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 Contents
I. A Brief Introduction – Concept and Rules of Statutory Interpretation ................................... 4

1. Concept and Need ................................................................................................................ 4

2. Rules of Statutory Interpretation .......................................................................................... 5

2.2.1 The Literal Rule ........................................................................................................ 5

2.2.2 The Golden Rule ....................................................................................................... 5

2.2.3 The Mischief Rule..................................................................................................... 6

II. Principles of Interpretation - Purposive Approach ................................................................. 7

III. Judicial Approach – In India and Internationally ................................................................ 9

3.1 Indian Judiciary ................................................................................................................ 9

3.2 International Approach ................................................................................................... 12

IV. Conclusions ........................................................................................................................ 16

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 I. A BRIEF INTRODUCTION – CONCEPT AND RULES OF
STATUTORY INTERPRETATION

1. CONCEPT AND NEED

The term statutory interpretation refers to the action of a court in trying to understand and
explaining the meaning of a piece of legislation. Many cases go to appeal on a point of
interpretation, Indeed, Lord Hailsham, a senior English judge, once said that “probably 9 out of 10
cases heard by the Court of Appeal and the House of Lords turn upon or involve the meaning of
words contained in statute or secondary legislation.”

Why is this the case? First, laws must be drafted in general terms and must deal with both present
and future situations. Often, a law which was drafted with one particular situation in mind will
eventually be applied to quite different situations. A classic example is the UK Criminal Justice
Act, part of which was originally designed to curb illegal warehouse parties but which was later
used to crush demonstrations, often involving people from very different backgrounds to those
attending the so-called raves.

Legislation is drawn up by draftsmen, and a draftsman’s capacity to anticipate the future is

limited. He may not foresee some future possibility, or overlook a possible misinterpretation of
the original intentions of the legislation. Another problem is legislation often tries to deal with
problems that involve different and conflicting interests.1

Both legal and general English contain many words with more than one meaning. In fact, some of
the terms in TransLegal’s Legal English Dictionary have seven or more distinct definitions. With
this being the case, even the best drafted legislation can include many ambiguities. This is not the
fault of the draftsman, simply a reflection of the fact that where people look at a text from different
points of view they will naturally find different meanings in the language used.2

1
Ranjan, R. (n.d.). The rules of statutory interpretation (2) - TransLegal. [online] TransLegal. Available at:
https://www.translegal.com/lesson/statutory-interpretation-2 [Accessed 1 Sep. 2018].
2
Ibid.

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 2. RULES OF STATUTORY INTERPRETATION
Judges in England generally apply three basic rules of statutory interpretation, and similar rules
are also used in other common law jurisdictions. The literal rule, the golden rule and
the mischief rule. Although judges are not bound to apply these rules, they generally take one of
the following three approaches, and the approach taken by any one particular judge is often a
reflection of that judge’s own philosophy.

2.2.1 THE LITERAL RULE

Under the literal rule (also: the ordinary meaning rule; the plain meaning rule), it is the task of
the court to give a statute’s words their literal meaning regardless of whether the result is sensible
or not. In a famous judgment, Lord Diplock in Duport Steel v Sirs (1980) said “The courts may
sometimes be willing to apply this rule despite the manifest absurdity that may result from the
outcome of its application.” The literal rule is often applied by orthodox judges who believe that
their constitutional role is limited to applying laws as enacted by Parliament. Such judges are wary
of being seen to create law, a role which they see as being strictly limited to the
elected legislative branch of government. In determining the intention of the legislature in
passing a particular statute, this approach restricts a judge to the so called black letter of the law.
The literal rule has been the dominantapproach taken for over 100 years.3

2.2.2 THE GOLDEN RULE

The golden rule (also: the British rule) is an exception to the literal rule and will be used where
the literal rule produces the result where Parliament’s intention would be circumvented rather
than applied. In Grey v Pealson (1857), Lord Wensleygale said : “The literal rule should be used
first, but if it results in absurdity, the grammatical and ordinary sense of the words may be
modified, so as to avoid absurdity and inconsistency, but no further.”

One example of the application of the golden rule is the case of R v Allen
– Defendant is charged with bigamy, an offence prohibited in Offences Against Persons Act
1861 which reads “whoever is married, marries another commits bigamy.” The court held that the
word “marries” need not mean a contract of marriage as it was impossible for a person who is

3
TheFreeDictionary.com. (n.d.). literal interpretation. [online] Available at:
https://www.thefreedictionary.com/literal+interpretation [Accessed 2 Sep. 2018].

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already married to enter into another valid contract of marriage. Hence, the court interpreted it as
“going through marriage ceremony”.4

2.2.3 THE MISCHIEF RULE

The final rule of statutory interpretation is the mischief rule, under which a judge attempts to
determine the legislator’s intention; what is the “mischief and defect” that the statute in question
has set out to remedy, and what ruling would effectively implement this remedy? The classic
statement of the mischief rule is that given by the Barons of the Court of Exchequer in Heydon’s
Case (1854): “…for the sure and true interpretation of all statutes in general, four things are to be
discerned and considered:

1. What was the common law before the making of the Act?
2. What was the mischief and defect for which the common law did not provide?
3. What remedy the Parliament hath resolved and appointed to cure the disease of
the Commonwealth?
4. The true reason of the remedy; and then the office of all the judge is always to make
such construction or shall suppress subtle inventions and evasions for continuance of the mischief
and pro private commodo, and to add force and life to the cure and remedy, according to the true
intent of the makers of the Act, pro bono publico.5

This system of relying on external sources such as the common law in determining the true
intention of the parliament is now seen as part of the purposive approach. Although the literal
approach has been dominant in common law systems for over a century, judges now appear to be
less bound by the black letter of the law and are more willing to try to determine the true intention
of the Parliament. The task of the judge is now seen as being give effect to the legislative purpose
of the statute in question.6

4
Ibid.
5
Supra note 1.
6
Supra note 3.

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 II. PRINCIPLES OF INTERPRETATION - PURPOSIVE APPROACH

1. what was the common law before the making of the Act;
2. what was the mischief and defect for which the common law did not provide;
3. what remedy Parliament has resolved and appointed to cure the disease of the
commonwealth;
4. the true reason of the remedy, end then the office of all the judges is always to
make such construction as shall:
a. suppress the mischief and advance the remedy;
b. suppress subtle inventions and evasions for the continuance of the mischief pro private-
commode (for private benefit); and
c. add force and life to the cure and remedy according to the true intent of the makers of the
Act pro publico (for the public good)."7

The principles of statutory interpretation are well settled. Where the words of the statute are clear
and unambiguous, the provision should be given its plain and normal meaning, without adding or
rejecting any words. Departure from the literal rule, by making structural changes or substituting
words in a clear statutory provision, under the guise of interpretation will pose a great risk as the
changes may not be what the Legislature intended or desired. Legislative wisdom cannot be
replaced by the Judge's views. As observed by the Supreme Court in somewhat different context:
"When a procedure is prescribed by the Legislature, it is not for the court to substitute a different
one according to its notion of justice. When the Legislature has spoken, the Judges cannot afford
to be wiser." There is however an exception to this general rule. Where the words used in the
statutory provision are vague and ambiguous or where the plain and normal meaning of its words
or grammatical construction thereof would lead to confusion, absurdity, repugnancy with other
provisions, the courts may, instead of adopting the plain and grammatical construction, use the
interpretative tools to set right the situation, by adding or omitting or substituting the words in the
Statute. When faced with an apparently defective provision in a statute, courts prefer to assume

7
Halsbury's Laws of England, Volume 44(1), fourth reissue, para 1474, pp 906-07.

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that the draftsman had committed a mistake rather than concluding that the Legislature has
deliberately introduced an absurd or irrational statutory provision. Departure from the literal rule
of plain and straight reading can however be only in exceptional cases, where the anomalies make
the literal compliance of a provision impossible, or absurd or so impractical as to defeat the very
object of the provision.

Maxwell on Interpretation of Statutes (12th Edn., page 228), under the caption 'modification of the
language to meet the intention' in the chapter dealing with 'Exceptional Construction' states the
position succinctly:

Where the language of a statute, in its ordinary meaning and grammatical construction, leads to
a manifest contradiction of the apparent purpose of the enactment, or to some inconvenience or
absurdity, hardship or injustice, which can hardly have been intended, a construction may be put
upon it which modifies the meaning of the words, and even the structure of the sentence. This
may be done by departing from the rules of grammar, by giving an unusual meaning to
particular words, or by rejecting them altogether, on the ground that the legislature could not
possibly have intended what its words signify, and that the modifications made are mere
corrections of careless language and really give the true meaning. Where the main object and
intention of a statute are clear, it must not be reduced to a nullity by the draftman's unskilfulness
or ignorance of the law, except in a case of necessity, or the absolute intractability of the
language used.8

8
Maxwell on Interpretation of Statutes (12th Edn., page 228), International Publicaton House, 2013.

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 III. JUDICIAL APPROACH – IN INDIA AND INTERNATIONALLY
3.1 INDIAN JUDICIARY
Supreme Court in Tirath Singh v. Bachittar Singh approved and adopted the said approach.
In Shamrao V. Parulekar v. District Magistrate, Thana, Bombay the Court reiterated the principle
from Maxwell:

“if one construction will lead to an absurdity while another will give effect to what commonsense
would show was obviously intended, the construction which would defeat the ends of the Act
must be rejected even if the same words used in the same section, and even the same sentence,
have to be construed differently. Indeed, the law goes so far as to require the Courts sometimes
even to modify the grammatical and ordinary sense of the words if by doing so absurdity and
inconsistency can be avoided.”9

In Molar Mal v. Kay Iron Works (P) Ltd. Court while reiterating that courts will have to follow
the rule of literal construction, which enjoins the court to take the words as used by the Legislature
and to give it the meaning which naturally implies, held that there is an exception to that rule. This
Court observed:

“That exception comes into play when application of literal construction of the words in the
statute leads to absurdity, inconsistency or when it is shown that the legal context in which the
words are used or by reading the statute as a whole, it requires a different meaning.”10

In Mangin v. Inland Revenue Commission the Privy Council held:

The object of the construction of a statute, be it to ascertain the will of the legislature, it may be
presumed that neither injustice nor absurdity was intended. If, therefore a literal interpretation

9
1991 A.L.R. 20 (Mad.) 83.
10
(1994) (3) S.C.C. 1, 12.

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would produce such a result, and the language admits of an interpretation which would avoid it,
then such an interpretation may be adopted.11

A classic example of correcting an error committed by the draftsman in legislative drafting is the
substitution of the words 'defendant's witnesses' by this Court for the words 'plaintiff's witnesses'
occurring in Order VII Rule 14(4) of the Code, in Salem Bar-II:

Order VII relates to the production of documents by the plaintiff whereas Order VIII relates to
production of documents by the defendant. Under Order VIII Rule 1A(4) a document not
produced by defendant can be confronted to the plaintiff's witness during cross-examination.
Similarly, the plaintiff can also confront the defendant's witness with a document during cross-
examination. By mistake, instead of 'defendant's witnesses', the words 'plaintiff's witnesses' have
been mentioned in Order VII Rule (4). To avoid any confusion, it was directed that till the
legislature corrects the mistake, the words 'plaintiff's witnesses, would be read as 'defendant's
witnesses' in Order VII Rule 4.12

Justice G.P. Singh extracts four conditions that should be present to justify departure from the
plain words of the Statute, in his treatise "Principles of Statutory Interpretation" (12th Edn. - 2010,
Lexis Nexis - page 144) from the decision of the House of Lords in Stock v. Frank Jones (Tipton)
Ltd.:

“...a court would only be justified in departing from the plain words of the statute when it is
satisfied that (1) there is clear and gross balance of anomaly; (2) Parliament, the legislative
promoters and the draftsman could not have envisaged such anomaly and could not have been
prepared to accept it in the interest of a supervening legislative objective; (3) the anomaly can

11
(1994) (3) S.C.C. 1, 12.
12
Supra note 9.

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 be obviated without detriment to such a legislative objective; and (4) the language of the statute
is susceptible of the modification required to obviate the anomaly.”13

It is now well-settled that for the purpose of interpretation of statute the same has to be in its
entirety. Furthermore, in a case of this nature, principles of purposive construction must come into
play. In Chief Justice of A.P. v. L.V.A. Dikshitulu , the Court observed:

"The primary principle of interpretation is that a Constitutional or statutory provision should be

construed "according to the intent of they that made it" (Coke). Normally, such intent is gathered
from the language of the provision. If the language, or the phraseology employed by the
legislation is precise and plain and thus by itself proclaims the legislative intent in unequivocal
terms, the same must be given effect to, regardless of the consequences that may follow. But if
the words used in the provision are imprecise, protean or evocative or can reasonably bear
meanings more than one, the rule of strict grammatical construction ceases to be a sure guide to
reach at the real legislative intent. In such a case, in order to ascertain the true meaning of the
terms and phrases employed, it is legitimate for the Court to go beyond the arid literal confines
of the provision and to call in aid other well-recognised rules of construction, such as its
legislative history, the basic scheme and framework of the statute as a whole, each portion
throwing light, on the rest, the purpose of the legislation, the object sought to be achieved, and
the consequences that may flow from the adoption of one in preference to the other possible
interpretation.14

In Kehar Singh v. State (Delhi Admn.) Court held:

"...But, if the words are ambiguous, uncertain or any doubt arises as to the terms employed, we
deem it as our paramount duty to put upon the language of the legislature rational meaning. We
then examine every word, every section and every provision. We examine the Act as a whole. We
examine the necessity which gave rise to the Act. We look at the mischiefs which the legislature
intended to redress. We look at the whole situation and not just one-to-one relation. We will not

13
"Principles of Statutory Interpretation" (12th Edn. - 2010, Lexis Nexis - page 144)
14
(1994) (3) S.C.C. 1, 12.

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 consider any provision out of the framework of the statute. We will not view the provisions as
abstract principles separated from the motive force, behind. We will consider the provisions in
the circumstances to which they owe their origin. We will consider the provisions to ensure
coherence and consistency within the law as a whole and to avoid undesirable consequences."15

In District Mining Officer v. Tata Iron & Steel Co , Supreme Court stated:

"The legislation is primarily directed to the problems before the legislature based on information
derived from past and present experience. It may also be designed by us a of general words to
cover similar problems arising in future. But, from the very nature of things, it is impossible to
anticipate fully in the Varied situations arising in future in which the application of the
legislation in hand may be called for and words chosen to communicate such indefinite referents
are bound to be in many cases, lacking in clarity and precision and thus giving rise to
controversial questions of construction. The process of construction combines both literal and
purposive approaches. In other words, the legislative intention i.e. the true or legal meaning of
an enactment is derived by considering the meaning of the words used in the enactment in the
light of any discernible purpose or object which comprehends the mischief and its remedy to
which the enactment is directed."16

It is well known that an interpretation of the statute which harmonizes with its avowed object is
always to be accepted than the one which dilutes it.

3.2 INTERNATIONAL APPROACH

he problem of statutory interpretation has been a matter of considerable judicial debate in almost
all common law jurisdictions. Felix Frankfurter dealt with this problem rather comprehensively
in his Sixth Annual Benjamin N. Cardozo Lecture. The learned Judge opined:

“Anything that is written may present a problem of meaning, and that is the essence of the

15
(1994) (3) S.C.C. 1, 12.
16
(1994) (3) S.C.C. 1, 12.

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 business of judges in construing legislation. The problem derives from the very nature of words.
They are symbols of meaning.”

About what the words connote, there is a very illuminating discussion by Friedrich Bodmer, a
Swiss Philologist in his treaties "The Loom of Language". Bodmer, who was a Professor in the
Massachusetts Institute of Technology, said:

“Words are not passive agents meaning the same thing and carrying the same value at all times
and in all contexts. They do not come in standard shapes and sizes like coins from the mint, nor
do they go forth with a degree to all the world that they shall mean only so much, no more and no
less. Through its own particular personality each word has a penumbra of meaning which no
draftsman can entirely cut away. It refuses to be used as a mathematical symbol.”
The aforesaid formulation by Professor Bodmer was cited with approval by the Constitution Bench
of Supreme Court of India in S.C. Advocates-on-Record Association & Ors., v. Union of India.
Justice Holmes in Towne v. Eisnerthought in the same way by saying:
"a word is not a crystal, transparent and unchanged; it is the skin of a living thought and may vary
greatly in colour and content according to the circumstances and the time in which it is used.”17

Therefore, about the problem of interpretation we may again go back to what Justice Frankfurter
said in the aforesaid article. This is of considerable importance. The learned Judge said:
“...The process of construction, therefore, is not an exercise in logic or dialetic: The aids of formal
reasoning are not irrelevant; they may simply be inadequate. The purpose of construction being
the ascertainment of meaning, every consideration brought to bear for the solution of that problem
must be devoted to that end alone...”18

Lord Greene, Master of Rolls, also gave the same direction in Re, Bidie (deceased). In the words
of Master of Rolls the technique should be - to read the statue as a whole and ask oneself the

17
Supra note 7.
18
Ibid.

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question: 'In this state, in this context, relating to this subject - matter, what is the true meaning of
that word'.

About the development of purposive approach, Bennion on Statutory Interpretation (Fifth Edition)
has traced its origin: General judicial adoption of the term 'purposive construction' is recent, but
the concept is not new. Viscount Dilhorne, citing Coke, said that while it is now fashionable to
talk of a purposive construction of a statute the need for such a construction has been recognised
since the seventeenth century. In fact the recognition goes considerably further back than that.

In this connection, the opinion of Lord Diplock in Jones v. Wrotham Park Settled Estates is very
pertinent, the learned Law Lord said: “I am not reluctant to adopt a purposive construction where
to apply the literal meaning of the legislative language used would lead to results which would
clearly defeat the purposes of the Act. But in doing so the task on which a court of justice is
engaged remains one of construction, even where this involves reading into the Act words which
are not expressly included in it.”

In coming to the aforesaid conclusion the learned Judges relied on the famous dictum of Lord
Denning in Seaford Court Estates Ltd. v. Asher - wherein the learned Judge stated the position
thus: “...A Judge should ask himself the question how, if the makers of the Act had themselves
come across this rock in the texture of it, they would have straightened it out? He must then do so
as they would have done. A judge must not alter the material of which the Act is woven, but he
can and should iron out the creases.”

In Francis Bennion's Statutory Interpretation, purposive construction has been described in the
following manner:A purposive construction of an enactment is one which gives effect to the
legislative purpose by-

▪ following the literal meaning of the enactment where that meaning is in

accordance with the legislative purpose (in this Code called a purposive-
and-literal construction), or

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 ▪ applying a strained meaning where the literal meaning is not in accordance
with the legislative purpose (in the Code called a purposive-and- strained
construction).

In 'The Interpretation and Application of Statutes', Reed Dickerson, discussed the subject while
dealing with the importance of context of the statute in the following terms:

... The essence of the language is to reflect, express, and perhaps even affect the conceptual matrix
of established ideas and values that identifies the culture to which it belongs. For this reason,
language has been called "conceptual map of human experience.

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 IV. CONCLUSIONS
The term statutory interpretation refers to the action of a court in trying to understand and
explaining the meaning of a piece of legislation. Many cases go to appeal on a point of
interpretation, Indeed, Lord Hailsham, a senior English judge, once said that “probably 9 out of 10
cases heard by the Court of Appeal and the House of Lords turn upon or involve the meaning of
words contained in statute or secondary legislation.”

Why is this the case? First, laws must be drafted in general terms and must deal with both present
and future situations. Often, a law which was drafted with one particular situation in mind will
eventually be applied to quite different situations. A classic example is the UK Criminal Justice
Act, part of which was originally designed to curb illegal warehouse parties but which was later
used to crush demonstrations, often involving people from very different backgrounds to those
attending the so-called raves.

Legislation is drawn up by draftsmen, and a draftsman’s capacity to anticipate the future is

limited. He may not foresee some future possibility, or overlook a possible misinterpretation of
the original intentions of the legislation. Another problem is legislation often tries to deal with
problems that involve different and conflicting interests.19

Both legal and general English contain many words with more than one meaning. In fact, some of
the terms in TransLegal’s Legal English Dictionary have seven or more distinct definitions. With
this being the case, even the best drafted legislation can include many ambiguities. This is not the
fault of the draftsman, simply a reflection of the fact that where people look at a text from different
points of view they will naturally find different meanings in the language used.20

Rules of Statutory Interpretation

Judges in England generally apply three basic rules of statutory interpretation, and similar rules
are also used in other common law jurisdictions. The literal rule, the golden rule and
the mischief rule. Although judges are not bound to apply these rules, they generally take one of

19
Ranjan, R. (n.d.). The rules of statutory interpretation (2) - TransLegal. [online] TransLegal. Available at:
https://www.translegal.com/lesson/statutory-interpretation-2 [Accessed 1 Sep. 2018].
20
Ibid.

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the following three approaches, and the approach taken by any one particular judge is often a
reflection of that judge’s own philosophy.

The Literal Rule

Under the literal rule (also: the ordinary meaning rule; the plain meaning rule), it is the task of
the court to give a statute’s words their literal meaning regardless of whether the result is sensible
or not. In a famous judgment, Lord Diplock in Duport Steel v Sirs (1980) said “The courts may
sometimes be willing to apply this rule despite the manifest absurdity that may result from the
outcome of its application.” The literal rule is often applied by orthodox judges who believe that
their constitutional role is limited to applying laws as enacted by Parliament. Such judges are wary
of being seen to create law, a role which they see as being strictly limited to the
elected legislative branch of government. In determining the intention of the legislature in
passing a particular statute, this approach restricts a judge to the so called black letter of the law.
The literal rule has been the dominant approach taken for over 100 years.21

The Golden Rule

The golden rule (also: the British rule) is an exception to the literal rule and will be used where
the literal rule produces the result where Parliament’s intention would be circumvented rather
than applied. In Grey v Pealson (1857), Lord Wensleygale said : “The literal rule should be used
first, but if it results in absurdity, the grammatical and ordinary sense of the words may be
modified, so as to avoid absurdity and inconsistency, but no further.”

One example of the application of the golden rule is the case of R v Allen
– Defendant is charged with bigamy, an offence prohibited in Offences Against Persons Act
1861 which reads “whoever is married, marries another commits bigamy.” The court held that the
word “marries” need not mean a contract of marriage as it was impossible for a person who is
already married to enter into another valid contract of marriage. Hence, the court interpreted it as
“going through marriage ceremony”.22

21
TheFreeDictionary.com. (n.d.). literal interpretation. [online] Available at:
https://www.thefreedictionary.com/literal+interpretation [Accessed 2 Sep. 2018].
22
Ibid.

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The Mischief Rule

The final rule of statutory interpretation is the mischief rule, under which a judge attempts to
determine the legislator’s intention; what is the “mischief and defect” that the statute in question
has set out to remedy, and what ruling would effectively implement this remedy? The classic
statement of the mischief rule is that given by the Barons of the Court of Exchequer in Heydon’s
Case (1854): “…for the sure and true interpretation of all statutes in general, four things are to be
discerned and considered:

1. What was the common law before the making of the Act?
2. What was the mischief and defect for which the common law did not provide?
3. What remedy the Parliament hath resolved and appointed to cure the disease of
the Commonwealth?
4. The true reason of the remedy; and then the office of all the judge is always to make
such construction or shall suppress subtle inventions and evasions for continuance of the mischief
and pro private commodo, and to add force and life to the cure and remedy, according to the true
intent of the makers of the Act, pro bono publico.23

This system of relying on external sources such as the common law in determining the true
intention of the parliament is now seen as part of the purposive approach. Although the literal
approach has been dominant in common law systems for over a century, judges now appear to be
less bound by the black letter of the law and are more willing to try to determine the true intention
of the Parliament. The task of the judge is now seen as being give effect to the legislative purpose
of the statute in question.24

23
Supra note 1.
24
Supra note 3.

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 BIBLIOGRAPHY
• Ranjan, R. (n.d.). The rules of statutory interpretation (2) - TransLegal. [online]
TransLegal. Available at: https://www.translegal.com/lesson/statutory-interpretation-2

• Halsbury's Laws of England, Volume 44(1), fourth reissue, para 1474,

• Maxwell on Interpretation of Statutes (12th Edn., page 228), International Publicaton

House, 2013.

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