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“DECODING THE LAW: A COMPREHENSIVE GUIDE TO THE ART OF LITERAL INTERPRETATION”
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Article Details
“DECODING THE LAW: A COMPREHENSIVE
GUIDE TO THE ART OF LITERAL INTERPRETATION”
AUTHORED BY - DIVITA VASHISHT
O.P. JINDAL GLOBAL UNIVERSITY, INDIA
ABSTRACT
In the world of globalisation, it is
equally important to communicate to each other. Would this be possible without
an ordinary meaning given to the language spoken? No. The same goes for the
language of law. The purpose of interpreting a statute ‘is to unlock the locks
put by the Legislature’. It is not expected from courts to interpret
statutes arbitrarily, and due to precedents or the courts'
constant practise, definite principles have surfaced. These principles
are referred to as "rules of interpretation." In a case
at hand, the court applies any of the rules that result in an outcome which
fulfils its sense of justice. The literal rule is one of the oldest
approaches to interpretation used by the courts. The judges, the lawyers, a
layman are capable to understand it when there are no ambiguities under a
statutes. But there are circumstances when a particular statues conveys more
than one meaning. Within cases of ambiguity and in recent times, there are
evidences that the courts take a different rule. When a particular rule is assumed
to be valid enough for a given case, it is equally important to also
recognise the assumption. The paper would first discuss the literal rule in
detail with its criticisms. Secondly, this paper would address the
significance of removing ambiguities in language and how the purposive rule of
interpretation aids in right interpretation of law, thereby preventing invalid
choices made by courts and also would study nuances of transition from a
literal rule to purposive interpretation.
LITERAL RULE OF INTERPRETATION
The language of law is intended to be
crystal clear so that it leaves no inconsistency in its interpretation and
to ensure that the individuals understand it, for the fact that they are
governed through it. But even so, years of refinement and the efforts of judges
and attorneys to make the legal language lucid have made it even
harder to comprehend. However, there is one such interpretation that needs no
efforts to fathom. The grammatical interpretation also known as the Literal
Rule of Interpretation derived its significance from the ordinary meaning of
language. Within this type of interpretation, "words" are
employed in their precise nature and are construed as per their
"literal" meaning or the glossary definition of the term, in other
words, their direct context. Lord Atkinson in Corp of the City of
Victoria v Bishop of Vancouver Island explained the dialect ‘Literal
Meaning’. He alludes that in the process of constructing a statute, its words
should be interpreted in their ordinary or grammatical meaning, and any sort of
departure from it cannot be done unless there is plurality in the context, or
in the object of the statute in which they occur or in the circumstances in
which they are taken, show that they were used in a special way apart from
their natural meaning.[1]
The notion behind literal rule of interpretation is that the words used
themselves do the justice, and it is always preferred when the courts interpret
the language expressed by the legislature and the intention behind their minds for
envisaging the same. The cardinal rule of interpretation is to give effect to
the grammatical meaning of the text over all kinds of interpretation.
When the grammatical construction is straightforward and unambiguous then
it is the duty of courts to respect the intention of the legislature and
literal construction must prevail, unless there is a compelling and
obvious justification to do otherwise. The courts have established that
provisions of the act must be interpreted in conformity with the true meaning
of the phrases and expressions that must be read in view of the
"Statement of the Objects, Reasons and the Preamble of the Act."[2] It
is that the words of the statute must be prima facie be adhered to their
plain and ordinary meaning.[3] A
confined and exhaustive definition shall only be broadened or moulded to
incorporate meanings which are not rigidly suggesting in the sense of the words
as determined.[4]
Furthermore, there are instances where the legislature intention doesn’t
pertain to suing words or expressions in their legal sense and rather to apply
it in their ordinary dictionary or literal meaning.[5]
For instance, we know that in contracts the term ‘consideration’ means
‘something in return in monetary terms’; this is the legal context of the word
‘consideration’ whereas the English language suggests it differently. The court
in referring to one of the cases i.e. Jones v Tower Boot Co Ltd.
construed Section 32 of the Race Relations Act, 1976 that provided for
penalising actions against Racial Discrimination done by a person in his
‘course of employment’.[6]
Now the words ‘in the course of employment’ in tort law has a technical meaning
holding vicarious responsibility, which would mean that the acts of employees
would also be answerable by his employer, and both of them could be held
responsible, whether or not it was done within the knowledge or approval of the
employer.[7]
But the meaning of the word if construed in the same sense upon Section 32
would largely frustrate the object of the Act to prevent racial discrimination.
Thus, the court interpreted these terms in their natural everyday meaning
because holding an employer responsible for the actions done by the employee
under the course of employee would defeat the principle of Morality in this
case.[8]
The Literal rule strategizes and
doesn’t go beyond what is written. Where the language of the law is definite
and unequivocal, it is not in the hands of the judges to go further
from that language or words and thereby, try to figure out what he might
have signified legislatively by using that text. It is only referring to
whatever the law states. Lastly, the first requirement while applying the rule
is to check from the start; what the aforementioned provision appears to say.
Secondly, when the provision is clear and explicit and the judge’s
interpretation is definite about the Parliament’s intention, then it is not
necessary to invoke other rules for the interpretation of statutes. We would
now look into some of the landmark cases where the courts have applied the
Literal Rule of Interpretation:
The issue before the Court in Motipur
Zamindari Company Private Limited v. State of Bihar was that whether
sugarcane can fall under the ambit of “green vegetables” or not; because if it
did, it would qualify as an exemption i.e. out from the Bihar Sales Tax
Act, 1947.[9]The
Court applied the literal rule of interpretation and determined that the term
"vegetable" should be interpreted as an everyday language indicating
a category of vegetables grown in a garden or in farms that can be consumed on
the table. Sugar cane is a grass, according to the dictionary in plain sense,
so it was not excluded from the Act.[10]
Similarly, was the issue in case of State
of West Bengal and others v. Washi Ahmed, where the court was asked
whether Ginger falls under the category of green vegetable. The sales
tax department-imposed tax over the respondents' sales of
"green ginger," claiming that green ginger is widely known
for adding flavour and taste to meals. [11]As
a result, applying the literal rule of interpretation, it was ruled out by the
court that green ginger falls under the definition of "vegetable" or
"tarkari." [12]
In B.N. Mutto v. T.K. Nandi, the
applicant was staying at government quarters and his own house was rented on
lease to the respondent. Afterward, the government decided that public
employees owning their own home should be asked to vacate the government
housing.[13]But,
prior to such notification, the applicant had already retired from his
services. The question was raised regarding if he could avail from Section
14A of the Delhi Rent Control Act. Some individuals were granted the right
to reclaim immediate possession of property (Government Plot) under Section 14A
under certain conditions, if met.[14]By
giving the section a mere ordinary reading, it was evident that the section
does not necessitate the individual occupying the premises given by the
government to be its officer. Thus, the applicant was given benefit under
section 14A.[15]
CRITICISMS
OF LITERAL RULE OF INTERPRETATION
Strict
compliance to this rule in some cases result in injustice or, at
occasions, leads to results that are completely incompatible with the
overall intent of the statute or practical wisdom. One of the drawbacks of
literal rule is the way it results in absurdity. The court sometimes can result
in a judgement and assign such an ‘interpretation to a statute’ that was not
ever intended by the parliaments. This same traditional literal interpretation
rule prevents the courts from attaching any meaning except than the
usual one. It blocks access to any sort of judicial innovation, thus putting
the Judges in a tight spot. Whereas if court follows the ordinary rule and believes
that perhaps the meaning is unethical, it can't avoid providing the
interpretation. Some criticise the above rule, claiming that it places too much
focus on the absurd notion that words and phrases have fixed meanings.
With changes in laws and regulations, provisions of the act cannot be construed
in line with the typical interpretation of long-ago used words. As a
result, it is no longer appropriate for the current times in some cases.
AMBIGUITY
IN LANGUAGE OF LAW
This topic is a thorough study of ambiguities
in legal language interpretation. It begins by discussing ambiguity in the
English dialect such as the word 'bank', for e.g., can relate to a
commercial bank or the edge of a body of water. Then it moves on to clarify how
uncertainty in language leads to ambiguity in the law through various case
laws.
The law is a profession of words[16].
The moment when the application of such words; is put into practice to govern
the spectrum of the profession; ambiguity is unavoidable. Ambiguity simply
means a misunderstanding pertaining to relevance of the language used. It takes
many different shapes or forms. Despite of all pure intention and
myriad initiatives by judges and attorneys to maintain the legal language
independent of any uncertainties, so that a layman can also
comprehend it, the meanings of the phrases and words seen in legal
documents may not always be straightforward and unambiguous. In real life
scenarios, the legal language can be such as to give two different meanings
i.e. uncertain or vague, or both. Such non-obvious meanings can be interpreted
by two different people in other ways. Legal documents can be ambiguous
not due to it being vague or uncertain, but because there is a factor in the
language of the document that generates more than one interpretation. As a
result, the law becomes ambiguous, defeating its intended purpose. Sometimes,
legal texts involve linguistic errors that cause them to have a different
connotation than intended. In the legal world, mistakes can have severe repercussions.
As a result, some theories classify legal texts as a special category of
text that require special interpretation in order to prevent the
possibility of harm caused by the application of 'wrong law'. However, the law
must be clear and concise as it's relevant to every user's everyday life,
and everyone has to understand it thoroughly in order to follow it. Ambiguity
can occur for a variety of factors. It could be caused by a misunderstanding
of the drafter as well as the reader; whatever the reader interprets
from a document or provision might not be exactly what the
drafter intended to express by it. Other than this, ambiguous
interpretations could also be inferred from a statement which isn't
self-explanatory or precise i.e. an ambiguity induced by poor selection of
language.[17]
Many examples of ambiguity can
be found in the law and these circumstances occur when statutes or their
provisions are subject to more than one interpretation due to a legal
ambiguity. For instance, in the case of 'Bacchan Singh v. State of Punjab’
the accused was sentenced death penalty and it was held by the courts that such
sort of punishment must be given in the ‘Rarest of Rare cases’.[18]Moreover,
since there aren't any predefined criteria to describe it, the term "rarest
of the rare" is capable of being interpreted differently by different
courts. Also, due to its ambiguity, there is substantial uncertainty about
which cases fall in the ambit of this principle. Due to this ambiguity, it's
primarily a concern of the judge's understanding of the term as to whether the
specific case falls within the scope of the principle or not.[19]
The case of “Interstate
Commerce Commission v. Allen E. Kroblin, Inc”
involved clean chickens. There was confusion in this case regarding words
such as "agricultural product" and "manufactured product."
According to the details of this case, there was a fierce discussion about
whether clean and eviscerated chicken are manufactured or agricultural
products.[20]The
transportation of these chickens was under regulation process which needed
proper certification for interstate trade and commerce. Specific agricultural
commodities, such as vegetables and fruits, regular poultry, and
other agricultural goods that weren’t manufactured products, were exempted. Farmers
were able to use certified conveyances for most of their agricultural products
due to this exemption for non-manufactured products, with the exception of
eviscerated poultry, for which they were forced to use non-certified
conveyances, which were more expensive.[21]The
ICC asserted that dressed and eviscerated chicken was a manufactured item,
while the USDA contended it to be an agricultural commodity. The court
said that the terms 'agricultural commodities' and' manufactured
products' used in the agricultural deduction were ambiguous, and that
additional standards of the goods must be considered instead of construing
these vague words in order to try the issue at hand.[22]
In case of Calcutta
Gas co. v. State of West Bengal [23],
the notification was passed by the State Legislature Assembly to take over for
a time frame of five years; the management and control of the Oriental Gas
Company. It was contented that the State Legislature had no power to pass the
said notification. Entry 24 covers entirely industries on the State List,
whereas Entry 25 only covers the gas industry. If we would give effect to gas
words under Entry 24, then the object of entry 25 would get redundant.[24]The
appellant argued that the Industries Development and Regulation Act, 1951, had
already been passed by Parliament under Entry 52 of the Union list/List I,
which handled industries. Under s. 2 of the Central Act, it is declared
that in the public interest the Union shall acquire its control of the
industries provided in the First Schedule. The question arose, is the state legislature competent enough to pass
the Oriental Gas Company Act, 1960? This case demonstrates that legislative
bodies draft statutes, and there is always the potential of ambiguity,
dispute, and so on. It’s a principle that broad amplitude should be given to
the language of the entries. But some of the entries in the different List or
in the same List may overlap and sometimes their applicability tends to be in
conflict with each other[25].
It is then the duty of the Courts to bring harmony in the entries. Thus, the
court said to give broad meaning to each term and held that the gas industry
was clearly protected entirely by Entry 25 of the State List, where the State
had entire authority. As a result, the state had the power to enact legislation
in the specified area. Similarly, it was suggested that this would not restrict
the Parliament to enact laws in respect of gas and gas-works during war or
other national emergencies.
According to my analysis, when a
defect appears in the statute, the judge cannot simply wash of his hands and
blame it on the legislature, rather he should interpret it by finding the
intent behind it and what circumstances lead the legislature to draft that
particular law. It is a far-fetched idea and one can’t presuppose that a
legislative definition or a vocabulary, should be knowing whether a specific
item belongs to a particular classification or not, such as in case of ‘Interstate
Commerce Commission v. Allen E. Kroblin, Inc’. Furthermore,
while trying to deal with a legislation or maybe an administrative act, it
is beneficial to understand the purpose of the ordinance or act if it is making
two or conflicting sense and the legislature's intent must be in relation to
the ordinance's or act’s purpose. In cases of strict conflicts and when there
are two possible meanings; it is also the legislature's duty to intervene
and take the steps required to modify, nullify, or substitute the legislative
text. It is not reasonable to hold document drafters i.e. the
legislature always answerable for their choice of language because they
cannot necessarily envisage all the subtle nuances of language and all the
uncertainties. Thus, the duty of the courts comes into picture here to ultimately
interpret those words and allows for an explorations as to the conflicts. The
courts should not single-handedly look into the intent while deciding the case,
but as a whole should give it a practical meaning through analysing its text,
intent, objectively, purpose and the legislative history behind it.[26] If
two interpretations are possible, the court must choose the one that will
guarantee the seamless and cohesive operation of the constitution and reject
the one that will ultimately led to absurdity, cause practical frustration, or
render well-established regulations of existing legislation nugatory.[27]
TRANSITION FROM LITERAL RULE OF
INTERPRETATION TO PURPOSIVE RULE
It is necessary to eliminate such
forms of discrepancies and ambiguities, that could wrongfully shape the ruling
of the judge, where the intention behind imposing the law or a provision
in the law is vastly different. In such cases, one must forgo literal interpretation
of a statute in favour of a purposive rule of interpretation.
This interpretation is especially important when construing a law
which literally, gives it such an interpretation that wasn't
possible provided the legislature's intent in enacting the law in the
first place. In these kind of cases, it is better to departure
from strict literal interpretation and give heed to the legislature's
intention and its purpose behind enforcing such legislation. The loopholes
in literal rule interpretations directs the interpreters to prefer a
more purpose-oriented approach. The purposive rule gets broadly applicable
which allows the courts to take more situations in hands rather just simply
applying the words. This is how the gaps in language of the law can be filled.
It can also be applied in mysterious circumstances or cases, as it is applied
mainly on focusing the purpose of law.
PURPOSIVE INTERPRETATION
This rule popularly known as the
“mischief rule” and the “rule of purposive construction” enables consideration
of four concepts while interpreting an Act.[28]
Firstly, the common law prior of making this act. Secondly, the particular
defect or mischief that law couldn’t see. Thirdly, what sort of remedy has the
parliament invoked and wants to cure through enacting that particular act.
Fourthly, the honest reason for that remedy[29].
It can be ascertained that any regulations that the legislature passed must
have been enacted with a clear purpose and objective in mind. Within
the diverse interpretation rules, the rule of purposive interpretation of
statute is among the most important rule, that provides the greatest
preference to the object of a legislation and it also aids in achieving the
purpose of the statute while applying it. When there is a doubt
pertaining to the meaning in the words of a statute, the interpretation has to
be done in a way in which, they harmonise with each other, complement each
other with the ‘subject of the act’ and ‘object which legislature’ has in mind[30].
Moreover, with a purposive approach, the judges can go beyond the words
and the literal text, forming assumptions in which the interpretation
can be applied, to what is assumed to be the legislators' intention. The
judge's focus is to find an interpretation that applies the remedy provided in
order to remove the irregularity that arose while interpreting the statute
or provision literally[31].
In simpler words, at times once the words employed in a legal provision are
evasive and unclear, and where the clear and ordinary sense of the words,
or its grammatical interpretation, leads to uncertainty, absurdity, and
aversion of the interpreters, one should deport to the purposive rule of
interpretation. Courts in such cases can imply the use of different tools of
interpretation to rectify the scenario by introducing, removing, or
substituting the Statute's words. This is not meant to imply that the Court
believes the lawmaker enacted a bizarre or ambiguous clause; rather, it
believes the mistake was by the editors those formulated the provision in
such a manner that the provision became technically, grammatically inaccurate
or ambiguous. Furthermore, a word of caution is crucial when adapting a
purposive construction where the text of the law should not be sacrificed,
and it's impossible to re - write the law on the premise that everything that
supplements the objective of the Act has to have been authorised by the
legislature.[32]
Purposive construction has also been used in penal provisions to avoid
discrepancies, and surprisingly, such interpretation has also been used in the
construction of rules passed to effectuate international agreements and
conventions, as well as regulations aimed at providing impact to the council of
European Communities' directives.[33]
As per Justice G.P. Singh, multiple requirements
should be fulfilled in order to legitimise the departure from the plain
language of provisions; firstly, there must be presence of evident and rough
balance of discrepancies. Secondly, the legislators and the drafters couldn't
have anticipated such an abnormality. Thirdly, the anomaly could be
resolved without jeopardising said parliamentary objective and lastly, the
statute's wording is applicable to certain modifications needed to fix the
anomaly[34].
Moreover, if the phrases employed in the provision are not accurate, strong, or
indicative, have more than one possible interpretation, or
consists grammatical error that prevents the intention of the
legislature from being achieved, the Judge may apply his intelligence and think
beyond the literal interpretation of words and use other commonly
recognised interpretive standards such as the purposive rule, the legislative
history of the law, reason of its enactment, to reveal the real
purpose and significance behind expressions used. Therefore, it may be
concluded that to a point there is interpretive leeway, the
courts must try to provide the statute; an interpretation that aids in the
achievement of its supreme goal and thus restricts it from turning meaningless.
J. Ray emphasised in Keshavnanda
Bharti v. State of Kerala that a word's "meaning" is
determined by the regard that it is used in. The significance of a word is
derived not just from the context that it is employed, but from other words
used during analogous situations.[35]
In case of R.M.D. Chamarbaugwalla v. UOI
the meaning of "prize competitions" under the Prize Competition Act
of 1955 was said to include only instances where no substantive
abilities were associated. Thus, prize competitions requiring some skills
were exempted from the classification of "prize competition"
within the Act[36].
As a result, in the given case, the Apex Court used Heydon's Rule to
suppress the mischief that was meant to be rectified, as opposed to the
grammatical rule, which might had covered prize competition in which
no substantial skills were required for wining.[37]
In case of Royal College of Nursing v DHSS, The
Royal College of Nursing filed a lawsuit to challenge the validity of nurses
performing abortions. The Offences against the Person Act of 1861 renders it
an illegal act for anyone to perform abortions.[38]The Act
of 1967 stated that a medically enrolled professional, such as a
doctor enjoy a complete shield, to perform abortion if particular
requirements were fulfilled. Because of medical innovation, clinical
terminations were replaced by hormonal abortions, which were most commonly
conducted by nurses. [39]Thus, it
was held that it was lawful for nurses to conduct those abortions.
The Act was intended to put an end to illegal abortions in areas in which
healthcare was not available. Here the nurses' actions were outside the scope
of the 1861 Act's mischief and within the 1967 Act's defence.[40]
Thus, the instances given in the
above cases properly depict how an incorrigibly bad decision might had already
been made if the courts didn't apply purposive rule of interpretation.
These two case laws are perfect indications of the significance of purposeful
rule and its effective application in eliminating ambivalence from law.
CONCLUSION
When an ambiguity
occurs within legal arena, it causes great issue because it gives the
potential of reversing judicial decisions of cases of vital significance,
and it affects the system of providing justice in such a way that the
court sometimes makes unjustified, unfair, and absurd judgements. As a
result, it is a necessity to eliminate these ambiguities arising in
the fields of law. With the constant development and effort to end up
making the law, Acts, provisions and legal meanings free of ambiguities and
confusion, the language of law might get complicated and hard to comprehend;
for the public at large, as well as for legal scholars, intellectuals, legal
professionals and judicial officers. Judges presently employ a purposive
construction instead of literal rule of interpretation, trying to lend
legitimacy to the provisions of the Act or the Act as a
whole's purpose and tries to understand, a significant number of
international documents that pertain to the context within which law was
passed. In terms of the literal or purposeful strategy
of interpretation, while these rules may be effective in a certain
degree, it's also entirely possible of them being misunderstood and
cause considerable legal issues for India. Focusing on the literal rule, which
is a century old but also well interpretation standard under which the laws
must be interpreted in a way that they have no alternative interpretation
other than its ordinary and plain sense. Through this sense, we can draw
that there is vagueness as to what is exactly an ordinary or simple meaning.
There isn’t any standard through which we can predict it to a certain extent,
however to some cases there are possible plain meaning that one can construe.
Moving to the purposive approach, relevancy to the legislation’s intent, the
history behind the law, the remedy and the ambiguities are not always
transparent to be found, it can create a lot of complexities while applying the
purposive approach. Instances are present in India, where the High Courts have
applied the mischief rule but the Supreme Court reversed the same and departed
back to the literal approach. The ability to interpret, the plain meaning is to
comprehend ‘texts within the lines’ in ordinary sense, to read “thru the”
statute and in purposive to ‘examine the intention of the legislature, to
modify the ambiguities’, ‘to find the remedy and legislative history behind the
enacting of the law’, can be a task in the hands of judiciary and thus this
calls upon, other rules of interpretation for the present case scenarios.
[1] Corp of the City of Victoria v
Bishop of Vancouver Island, AIR 1921 PC 240
G. P
Singh, Principles of Statutory Interpretation, pp 65, 14th ed,
(LexisNexis Publications 2022)
[2] G. P Singh, Principles of
Statutory Interpretation, pp 90-91, 14th ed, (LexisNexis
Publications 2022)
[3] Ibid
[4] Cutter v Eagle Star Insurance Co
Ltd (1998) 4 ALL ER 417.,
G. P
Singh, Principles of Statutory Interpretation, pp 102, 14th ed,
(LexisNexis Publications 2022)
[5] G. P Singh, Principles of
Statutory Interpretation, pp 90, 14th ed, (LexisNexis Publications
2022)
[6] Jones v Tower Boot Co Ltd. (1997)
2 ALL ER 406;
G. P
Singh, Principles of Statutory Interpretation, pp 90, 14th ed,
(LexisNexis Publications 2022)
[7] Ibid
[8] Ibid
[9] Course Manual -Week 6- AIR 1962 SC 660
[10] Ibid
[11] Course Manual – week 6 -(1977) 2 SCC 246
[12] Ibid
[13]
Course Manual- week 6- (1979) 1 SCC 361
[14] Ibid
[16] David Mellinkoff, “The Language of
Law,” Little, Brown & Co., Boston, 1983.
[17] Himani Singh, American
International Journal of Research in Humanities, Language of law- Ambiguities
and Interpretation, 2(2), 2013, pp. 2.
[18] AIR 1980 SC 898
[19] Ibid
[20] Interstate Commerce Commission v.
Allen E. Kroblin, Inc113 F. Supp. 599 (1953)
[21] Ibid
[22] Ibid
[23] JGLS Course Manual – Week 7- AIR
1962 SC 1044
[24] Ibid
[26] JGLS Course Manual – Week 5
[27] G. P Singh, Principles of
Statutory Interpretation, pp 119, 14th ed, (LexisNexis Publications
2022)
[28] G. P Singh, Principles of
Statutory Interpretation, pp 96, 14th ed, (LexisNexis Publications
2022)
[29] G. P Singh, Principles of Statutory
Interpretation, pp 97, 14th
ed, (LexisNexis Publications 2022)
[30] G. P Singh, Principles of
Statutory Interpretation, pp 100, 14th ed, (LexisNexis Publications
2022)
[31] Ibid
[32] AIR 2004 SC 5080, G. P Singh,
Principles of Statutory Interpretation, pp
98, 14th ed, (LexisNexis Publications 2022)
[33] G. P Singh, Principles of
Statutory Interpretation, pp 100-101, 14th ed, (LexisNexis
Publications 2022)
[34] G.P Singh, ‘Principles of
Statutory Interpretation’,pp.144, 12th Edn.,(LexisNexis Publications, 2018)
[35] (1973) 4 SCC 225
[36] JGLS Course manual- week 6- AIR 1957 SC 628
[37] Ibid
[38] [1981] 2 WLR 279
[39] Ibid
Article Information
“DECODING THE LAW: A COMPREHENSIVE GUIDE TO THE ART OF LITERAL INTERPRETATION”
Authors: DIVITA VASHISHT
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/07/10
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
- Access Open Access
- License CC 4.0
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