Vous êtes sur la page 1sur 30

INTERPRETATION OF STATUTES PROJECT

NATIONAL LAW INSTITUTE UNIVERSITY, BHOPAL

INTERPRETATION OF STATUTES

THE ROLE OF PARLIAMENTARY AND LEGISLATIVE HISTORY IN


THE
INTERPRETATION OF INDIAN
STATUTES

SUBMITTED TO

PROF.DEBASHREE BANERJEE
ASSISTANT PROFESSOR OF LAW
NATIONAL LAW INSTITUTE

UNIVERSITY,

BHOPAL.

SUBMITTED BY:
AAKASH NARANG
2010-BALLB-34

1|Page

INTERPRETATION OF STATUTES PROJECT


TABLE OF CONTENTS

INTRODUCTION ........................................................................................................
........................ 3
UNDERSTANDING PARLIAMENTARY AND LEGISLATIVE
HISTORY ...................................................... 4
Parliamentary history
................................................................................................................. 4
Legislative history
.......................................................................................................................
4
IS LEGISLATIVE HISTORY BINDING
.................................................................................................. 4
LEGISLATIVE HISTORY AND LEGISLATIVE INTENTION
...................................................................... 5
REASONS FOR THE COURT'S USAGE OF LEGISLATIVE HISTORY
....................................................... 6
IS LEGISLATIVE HISTORY USAGE MOTIVATED BY DISAGREEMENT AMONG THE
JUSTICES.............. 7
THE USE
INDIAN

OF PARLIAMENTARY AND LEGISLATIVE HISTORY IN THE

INTERPRETATION

OF

STATUTES :WITH REFERENCE TO CASE LAWS


................................................................................... 8
...........................................................................................................
....................... 13
CONCLUSION

2|Page

INTERPRETATION OF STATUTES PROJECT

The essence of law lies in the spirit, not its letter, for the letter is
significant only as being the
external manifestation of the intention that underlies
it Salmond

INTRODUCTIO
N

Interpretation is as ancient as language. Highly structured rules of


interpretation

were developed at a very primitive stage of the Hindu

civilization. Interpretation is a knack of finding out the object of an


enactment by construing the words in their natural and ordinary meaning.
The Court is not supposed to interpret arbitrarily and thus certain basic
principles have been evolved. These principles are described as rules of
interpretation. Its object is to ascertain the intention of the legislature
communicated expressly or impliedly in the language used. As stated by
Salmond,
"By interpretation or construction is meant, the process by which the courts
seek to ascertain the meaning of the legislature through the medium of
authoritative forms in which it is expressed." When the words in a statute
are unclear. It is the task of the court to interpret it by referring to internal
as well as external aids. Apart from the intrinsic aids such as preamble and
the purview of the act, the court considers resources beyond the act,
these are called extrinsic aids. They mainly deal with the history of the act.
But this Historical setting are not used as an aid if the words are clear, if
the wordings are unclear, the historical setting may be taken into account in
order to achieve the proper construction. Historical setting comprises of
parliamentary history, historical facts, statement of
objects and reasons, report of expert
1
committees.

Ca. Rajkumar S. Adukia , Interpretation of Statutes

3|Page

INTERPRETATION OF STATUTES PROJECT


UNDERSTANDING

PARLIAMENTARY

AND

LEGISLATIVE

HISTORY

Parliamentary history stands for the procedure by which an act is enacted.


This contains conception of an idea, drafting of the bill, the debates, the
amendments etc. Speech made during over of the bill, amendments
contemplated during the progress of the bill are considered in parliamentary
history while the papers sited before the cabinet which pronounced for the
introduction of the bill are not germane since these papers are not sited
before the parliament.

Legislative
history
means (i)
The legislative antecedents of the statutory provision under
consideration ,i.e. corresponding provisions in previous enactment
3
since repealed and re-enacted with or without modification
(ii)
Pre parliamentary materials relating to the provision or the
statue in which it is contained ,e.g. reports of committees and
commission
(iii) Parliamentary materials

IS
LEGISLATIVE
HISTORY
BINDING
This notion is completely rejected. On contrary, there seems to be broad
consent that legislative history is just a tool with acts as a "guiding function"
for the courts. Variation of opinion arises regarding the relative weight to be
provided to the historical interpretative method in relation to other methods.
Advocates of legal discourse theory suggest a ranking that usually places
arguments based on legislative intent higher than others." furthermore,
increasing number of scholars are of the view that while a categorical duty
of the courts to stick to legislative history
might not exist, an obligation to refer the
4
materials does .

Justice A.K. Srivastava, Interpretation of Statutes


These are not the same thing as statutes in parimateria
4
Kenneth R. Dortzbach, Legislative History: The Philosophies of Justices Scalia and Breyer and the Use
of Legislative Historyb y the Wisconsin State Courts Volume 80, Issue 1 2006
3

4|Page

INTERPRETATION OF STATUTES PROJECT


LEGISLATIVE

HISTORY

AND

LEGISLATIVE

INTENTION

It is important to differentiate between legislative history and


legislative intent.
According

to

Black's

Law

Dictionary

legislative

intent

means

"the

design or plan that the legislature had at the time of enacting a statute."
It does not essentially reveal the meaning of each word; however it does
offer courts with a ways of selecting between competing interpretations.
Few schools of legislative interpretation offer that the court's obligation is to
determine and uphold the intention of the legislature; while some should the
existence of a collective intention and the necessity to determine such, even
if it does exist. For those in the former school, it is one mode to discern
legislative intent.
According to Black's Law Dictionary legislative
history means
"The back ground and events leading to the enactment of a statute,
including hearings committee reports, and floor debates."

In the beginning of the definition- "the background and events" is in fact


broader than the general perception of legislative history and, if it were not
restricted by the remainder of the definition, would appear to cover more
than the documents drafted during the legislative process.
It includes the "documents [legislatures generate] in the course of
7
enacting statutes.

Black's Law Dictionary, at 919.


Black's Law Dictionary, at 919.
7
Stacey l. Gordon and Helia Jazayeri, lost legislative Intent: What will montanans do when the meaning
Isn't plain? mont. L. Rev. 1 2009
6

5|Page

INTERPRETATION OF STATUTES PROJECT


REASONS
HISTORY

FOR THE

COURT'S USAGE

OF

LEGISLATIVE

Many scholars have tried to understand the motive of judges for citing
legislative history.The usage

of

legislative

history

is

motivated

by

combination of legal and ideological considerations.


Usually, the legal variables have a considerably greater impact on the
possibility of legislative history use than the ideological variables, but the
influence of the ideological variables cannot be denied. The intricacy of a
statute amplifies the likelihood of legislative history usage, while routinely
amended statutes are less prone to obtain such treatment.

The age of the statute is also relevant, but its outcome is neither linear nor
monotonic: extremely new and old statutes are less likely to extract
legislative history usage than statutes of intermediate age. The facts also
recommend that the usage of legislative history by one justice induces other
justices to respond in the similar kind.
With regard to the effect of ideological factors, liberal justices are usually
more likely than conservative

justices

Consequently, the rightward shift

to

use

legislative

in the ideological composition of the

Court has greatly corresponded with a fallof in the overall usage


of legislative history since the
9
mid-1980s.

history.

James J. Brudney &Corey Ditslear, Liberal Justices' reliance on Legislative history: Principle, Strategy,
and
The Scalia effect, 29 Berkeley J. Emp. &lab. L. 117 (2008)
9
David s. Law & David Zaring, law versus ideology: The Supreme Court and the Use of legislative
history51 Wm. & Mary l. Rev. 1653 2009-2010

6|Page

INTERPRETATION OF STATUTES PROJECT


IS LEGISLATIVE
AMONG THE
JUSTICES

HISTORY

USAGE

MOTIVATED

BY

DISAGREEMENT

There is one question that has to be delving into, to what limit, if any, do the
Justices refer to legislative history in order to retort to the arguments and
positions of other Justices?
Difference over the meaning of a statute enhances the usage of legislative
history. When Justices differ on the merits, it is expected from them to resort
to legislative history as a way of strengthening their own arguments, and
weakening those of the opponents.
It appears that Court's legislative history opinions yields little aid for this
hypothesis. Indeed, the opposite view can be:
Opinions for a unanimous Court are considerably more likely to refer to
legislative history than other kinds of opinions. However, this finding is
deceptive. It is an error to suppose that unanimity enhances legislative
history usage. Most of the majority opinions are unanimous opinions and
majority opinions-unanimous or else-are more likely to refer to legislative
history
than
are
10
opinions.

minority

10

David s. Law & David Zaring, Law versus Ideology: The Supreme Court and the Use of Legislative
history 51 Wm. & Mary l. Rev. 1653 2009-2010

7|Page

INTERPRETATION OF STATUTES PROJECT

THE
IN

USE
THE

OF

INTERPRETATION

PARLIAMENTARY

OF INDIAN

STATUTES:

AND

LEGISLATIVE

HISTORY

WITH REFERENCE TO CASE

LAWS

The parliamentary history may be referred for ascertaining the intention, but
not for construction, is pedantic. In fact all such material out freely to be
referred to and it is only by resort to such material that the object of the
legislation and how the legislature intended to achieve that object by the
11

particular statute can be correctly ascertained by the court . The reliance


which is placed on legislative history by the courts in determining an issue
can be seen in many case laws.
REFERENCE

TO PROCEEDING OF LEGISLATURE WHILE DISCUSSING THE CASE

LAWS
12

In Administrator-General of Bengal v. Premlal Mullick , the question was


whether a Hindu executor was a private executor within the meaning of
Section 31 Administrator Generals Act, 1874. The Privy Council held
reversing the High Court, that he was a private executor within the
meaning of Section 31 of the Act. Their Lordships observed:
The two learned Judges, who constituted the majority in the appellate
court, although they do not base their judgement upon them, refer to the
proceedings of the legislature which resulted in the passing of the Act of
1874 as legitimate age to the construction of Section 31. Their
Lordships think it right to expresses their dissent from that proposition. The
same reasons which exclude these considerations when the clauses of an
Act of the British Legislature are under
construction are equally cogent in the case of an
13
Indian statute .
14

In A. Thangla Kunju Musaliar v. M. Venkatachalarn Patti. , the questions


were whether Section
5(1) of the Travancore Taxation on Income (Investigation Commission) Act,
1124 (ME) was discriminatory and whether the Commission had authority
to investigate any case suomoto. It was observed:
The question at once arises as to why it was that the legislative authority
took the view that there were possible cases of tax evasion. It has been said
that although the statement of the objects and reasons appended to a bill is
not admissible as an aid to the construction of the Act as passed, yet, it
may be referred to only for the limited purpose of ascertaining the conditions
prevailing at

the time which necessitated the making


15
of the law .
11

Abbe R. Gluck, The States as Laboratories of Statutory Interpretation: Methodological Consensus


and the new modified textualism, 119 Yale l.J. 1750 (2014)
12
13
14
15

(1894-95) 22 IA 107: ILR (1895) 22 Cal 788


St. J. Langan, Maxwell on the Interpretation of Statutes (12th ed., 1969)
AIR 1956 SC 246: 29 ITR 349
Ibid at 3

8|Page

INTERPRETATION OF STATUTES PROJECT


16

In S C. Prashar v. Vasantsen Dwarkadas , S.K. Das, J. observed: The


statement of objects and moons for introducing a particular piece of
legislation cannot be used for interpreting the legislation if the words used
therein are clear enough. But the statement can be referred to for the
purposes ascertaining the circumstances which led to the legislation in order
17

to find out what was the mischief which the legislation aimed at .
And
Kapur,
J.
observed:
In construing an enactment and determining its true scope it is permissible to
have regard to all such factors as can legitimately be taken into account to
ascertain the intention of the legislature such as the history of the Act, the
reason which led to its being passed, the mischief which had to be cured as
well as Site cure as also the other provisions of the statute. This is the rule in
Heydon case". Taking this principle into account it appears that the object of
the amendment was to validate certain notices after the 1959 amendment
and after the lapse of eight years from the end of the assessment year and
also to nullify the effect of the Calcutta judgment in Debi Dutta Moody case.
18

In Balchand Jain v. State of M.P . for holding that an order for anticipatory
bail could be issued under Section 438, Criminal Procedure Code, 1973, to a
person apprehending arrest under Rule
184 of the Defence and Internal Security of India Rules, 1971, the Court
relied on the legislative history of the provision and on the
recommendations of the Law Commission and observations in the Law
Commission Report.
19

In Emperor v. Benoari Lal Sarma , Rownand, J.


observed:
Sen, J. ,has said in his judgement that it is not open to us to take into account
historical facts or any extraneous evidence either as to whether an
emergency existed or whether the Governor General had judged an
emergency to have arisen.
But according to Lord Halsbury in Powell v. Kempton Park Racecourse Co.,
such topics as the history of legislation and the facts which give rise to the
enactment may usefully be employed to interpret the meaning of the statute,
20
though they do not afford conclusive argument .
21

In State of Travancore-Cochin v. Bombay Co. Ltd , the respondents claimed


exemption from sales tax on the ground that their commodities to foreign
buyers in CIF or FOB contracts were sales "in the course of export of the
goods out of the territory of India within the meaning of Article 2860)(b) of
the Constitution. The High Court held in favour of the respondents. The

16
17

AIR 1963 SC 1356: (1964) 1 SCR 29

S.G.G. Edgar, Craies on Statute Law (1999)

18

(1976) 4 SCC 572 :1976 SCC (CRI) 689


AIR 1943 FC 36: 1943 FCR 96: (1943) 2 MAD LJ 207.
20
Vepa P. Sarathi, Interpretation of Statutes (4th ed., 2003)
19

21

AIR 1952 SC 366: 1952 SCR 1112

9|Page

INTERPRETATION OF STATUTES PROJECT


Supreme Court confirmed the Judgment,
but observed:
The use made by the learned Judges below of the speeches made by the
members of the Constituent Assembly in the course of the debates on the
Draft Constitution is unwarranted. That this form of extrinsic aid to the
interpretation of statutes is not admissible has been generally accepted in
England, and the same rule has been observed in the construction of Indian
statutes. The reason behind the rule was explained by one of us in A.K.
22

Gopalan v. State of Madras .;


thu
s:
'A speech made in the course of the debate on a Bill would at best be
indicative of the subjective intent of the speak, but it could not reflect the
inarticulate mental process lying behind the majority vote which carried the
Bill. Nor is it reasonable to assume that the minds of all the legislators
23

were in accord' ;
or as it is more tersely put in United States v. Trans-Missouri
24
Freight Assn .
'Those who did not speak may not have agreed with those who did; and
those who spoke might differ from each other.' The rule of exclusion has not
always been adhered to in America, and sometimes distinction is made
between using such material to ascertain the purpose of a statute and using
it for ascertaining its meaning. It would seem that the rule is adopted in
Canada and Australia.
25

In State of Bihar v. Khas Karanpura Collieries Ltd , while holding that


Section 30-A was inserted retrospectively by Act 15 of 1958 in the Mines and
Minerals (Regulation and Development) Act, 1957 and that it gave
temporary immunity front the applicability of Sections
9(0 and 16(1) of the Act to statutory mining leases until the Central
Government by notification made the provisions applicable with or without
modification to such leases, the Court observed: There can be no room for
doubt that the legislature intended that Section 30-A of the 1957 Act should
cover the aforesaid statutory leases as well. It will be apposite in this
connection to refer to the statement of objects and reasons given in the Bill
which sought to introduce Section 30-A in the 1957 Act with retrospective
effect which can be usefully resorted to for ascertaining the true scope of
the section and the extent of the protection afforded by it.
The Explanatory Memorandum attached to the Rules, is in the nature of
Statement of Objects and Reasons, and may be referred to P.S. Mahal v.
26
Union of India :
The aids which Parliament availed of such as the report of a special
committee preceding the enactment, existing state of the law, the

environment necessitating the enactment of the legislation, and the object


sought to be achieved, are useful for deciphering the real intention of the
Parliament and therefore cannot be denied to the court.
Therefore, reports of the committee which preceded the enactment of
legislation, reports of joint
22
23
24
25
26

AIR 1950 SC 27: (1950) 51 CRI LJ 1383


th
G.P. Singh, Principles Of Statutory Interpretation (11 Ed., 2008)
169 US 290 (1897).
(1976) 4 SCC 134
(1984) 4 SCC 545: 1985 SCC (L&S) 61

10 | P a g e

INTERPRETATION OF STATUTES PROJECT


parliamentary committees, report of a commission set up for collecting
information leading to the enactment are permissible external aids to
construction."
Report of joint Select Committee on Bill to amend the Act was referred to
see the object and purpose.
27
In Narain Khamman V. Parduman Kumar Jain ., it
was held that:
Though the Statement of Objects and Reasons accompanying a legislative
Bill cannot be used to determine the true meaning and effect of the
substantive provisions of a statute, it is permissible to refer to the Statement
of Objects and Reasons accompanying a Bill for the purpose of understanding
the background, the antecedent state of affairs, the surrounding
circumstances in relation to the statute, and the evil which the statute sought
to remedy.
In Union of India v. Tulsiram Patel, it was held: Support to the conclusion that
provision wholly excluded natural justice rules sought from factors such as
existence of provision in the Constitution since inception, its conscious
introduction after considerable debate and deliberation and democratic
ideology of the members of the Constituent Assembly.
In Bachan Singh v. State of Punjab, it was held: Constitutional law raises, in a
legal context, problems of economic, social, moral and political theory and
practice to which non-lawyers have much to contribute. When judges are
confronted by issues to which there is no legal answer, there is no reason
(other than a desire to maintain a fiction that the law pros-ides the answer)
for judicial discretion to be exercised in a vacuum, immune from non-legal
learning and extra-legal dispute. The judges must also consider while
deciding an issue of constitutional adjudication as to what would be the
moral, social and economic consequences of a decision either way.
In Special Reference No. z of 2002, Re, (Gujarat Assembly Election
28

matter) the debates in the Constituent Assembly on Articles 85 and 174


was looked into. Khare, J. (as the learned Chief Justice then was) referred to
29

Kesavananda Bharti cases in support of the proposition that the Constituent


Assembly Debates are permissible aids in construction to ascertain the
intention of the Constitution. The learned Judge observed as follows. One of
the known methods to discern the intention behind enacting a provision of
the Constitution and also to interpret the same is to
look into the historical legislative developments, Constituent Assembly al
provision. Debates or any enactment preceding the enactment of the
constitution.
In Kesavananda Bharti v. State of Kerala

30

, it was held that Constituent

Assembly Debates although not conclusive, yet show the intention of the
framers of the Constitution enacting provisions of the Constitution and
the Constituent Assembly Debates can throw light in
ascertaining the intention behind such provisions. Reference to Constituent
Assembly Debates in
27
28
29
30

(1985)
(2002)
(1973)
(1973)

1
8
4
4

SCC
SCC
SCC
SCC

11 | P a g e

1
237 AT P. 265
225: AIR 1973 SC 1461
225: AIR 1973 SC 1461

INTERPRETATION OF STATUTES PROJECT


interpreting a Constitutional provision: In Kesavananda Bharti v. State of
Kerala, H.R. Khanna, J. observed that the speeches in the Constituent
Assembly can be referred to for ascertaining the history of the constitutional
provision.
31

In Fagu Shaw v. State of W.B


Bhagwati, J. observed: It was at one
time thought that the speeches made by the members of the Constituent
Assembly in the course of the debates on the Draft Constitution were wholly
inadmissible as extraneous aids to the interpretation of a constitutional
provision, but of late there has been a shift in this position and following the
recent trends in juristic thought in some of the Western Countries and the
United State, the rule of exclusion rigidly followed in Anglo-American
jurisprudence has been considerably diluted.
32

In Ashoka Kumar Thakur v. Union of India , while justifying the separate


treatment given to minority institutions on the basis of constitutional
provision the Court observed that it is a settled position that in statutory
interpretation external aids have only a limited use. [I respectfully submit
that all aids external and internal are for the purpose of finding out the
object of a statutory provision or a word or phrase and that interpretation is
on the basis that it achieves that object and fits the context.] The only
comment I have to make is, instead of looking for the object if there is a
doubt, it is better to start with the object, because, I respectfully submit it
will lead to greater certainty, shorter judgments and no dissents.
The difference between consolidation and codification is that in the latter
both statutes and case law are integrated and
enacted as a whole after the necessary dovetailing, reconciliation
33
and distillation .

31

(1974) 4 SCC 152: 1974 SCC (CRI) 316


(2008) 6 SCC 1
33
Vepa P. Sarathi, Interpretation Of Statutes (4th Ed., 2003)
32

12 | P a g e

INTERPRETATION OF STATUTES PROJECT


CONCLUSIO
N

The conception that the legislative history must be sternly adhered to barely
has any advocates now a days. It is just a tool and "aid" or "guide" as
stated in Pepper v. Hart

34

-To better understand ambiguous provisions.

Now the discussion has thus swung towards ascertaining the significance
given to it. There exist no universal rules on the interpretation of legislative.
It is, though, a worthwhile duty for legal academics to examine the
possibilities and confines of a hierarchical order of different legislative
materials, ranging from preparatory reports by expert panels to commentary
by the Ministry. Besides, judges and legal scholars should observe the detail
process of how statutes are made in
order to be in a better position to consider
35
their value.
So far as the Indian judiciary is concerned they have tried to clear the poison
of these external sources by way of verdicts.
Debates have been referred many a time by the court in order to reach a
conclusion in a case. Recently SC has cleared that in S.R. Chaudhuri v. St. of
36

Punjab

That it is a settled position that debates in the Constituent Assembly may


be relied upon as an aid to interpret a Constitutional provision because it is
the function of the Court to find out the intention of the framers of the
Constitution.
But on speeches in K.S. Paripoornan v State of Kerala and
making a distinction

37

others while

between speeches of the mover and that of the other


members, they heldSpeeches made by the Members of the Parliament at the time of
consideration of a Bill, it has been held that they are not admissible as
extrinsic aids to the interpretation of the statutory provision. However,
speeches made by the mover of the Bill or Minister may be referred to for
the purpose of finding out the object intended to be achieved by the Bill
Regarding Law Commissions Report it was held that, It can also be referred
to where a particular

enactment

or

amendment

is

the

result

of

recommendations of Law Commission


Report
.

34

[1993] AC 593
Holger Fleischer, Comparative approaches to the use of Legislative History in Statutory
Interpretation, 60 am. J. Comp. L. 401 2012
36 (2001) 7 SCC 126
37 AIR 1995 SC 1012
35

13 | P a g e

INTERPRETATION OF STATUTES PROJECT


This judgment was further validated by The Supreme Court in Rosy and
another v State of Kerala and others

38

, where they considered Law

Commission of India, 41st Report for interpretation of section 200 (2) of


the Code of Criminal Procedure, 1898.
Finally as far as Statement of Objects and Reasons, accompanying a
legislative bill is concerned;
court has cleared that in Devadoss v. Veera Makali Amman
39
Koil Athalur
It is permissible to refer to it for understanding the background, the
antecedent state of affairs, the surrounding circumstances in relation to the
statute and the evil which the statute sought to remedy. But, it cannot be
used to ascertain the true meaning and efect of the substantive provision of
the statute. Thus it has been understood that there has been quite a bit
ambiguity in interpretation of statutes through legislature history. Hence it
needs to be adhered to and intent of the parliamentarian is of the prime
importance for understanding the intent of the legislature in
the framework of the
statutes.

38
39

(2000) 2 SCC 230


AIR 1998 SC 750

14 | P a g e

INTERPRETATION OF STATUTES PROJECT


BIBLIOGRAPHY
Articles Referred
Kenneth R. Dortzbach, Legislative History: The Philosophies of
Justices Scalia and
Breyer and the Use of Legislative History Volume 80, Issue 1 2006
Stacey l. Gordon and HeliaJazayeri,lost legislative Intent: What will
montanans do when the meaning Isn't plain? Mont. L. Rev. 1 2009
James J. Brudney&Corey Ditslear, Liberal Justices' reliance on
Legislative history: Principle, Strategy, and the Scalia effect, Berkeley
J. Emp. &lab. L. 117 (2008)
David s. Law & David Zaring, law versus ideology: The Supreme Court
and the Use of legislative history51 Wm. & Mary l. Rev. 1653 20092010
Abbe R. Gluck, The States as Laboratories of Statutory Interpretation:
Methodological
Consensus and the new modified textualism, 119 Yale l.J. 1750 (2014)
Holger Fleischer, Comparative approaches to the use of Legislative
History in Statutory
Interpretation, 60 am. J. Comp. L. 401 2012

15 | P a g e

INTERPRETATION OF STATUTES PROJECT

Internet Sources
http://www.jstor.org/stable/10.2307/23251934?
Search=yes&resultItemClick=true&searc
hText=The&searchText=role&searchText=of&searchText=parliament
ary&Statutes
http://ijtr.nic.in/articles/art21.pdf
http://www.lawyersclubindia.com/articles/Interpretation-ofStatute5430.aUwTmSwSN

http://www.nhs.vic.edu.au/library/legaldate/LegalDate_Vol_19_No_2_May_
2007.pdf
http://caaa.in/Image/Interpretation%20of%20Statutes.pdf

16 | P a g e