Project

On
“Beneficial Statutes & the Rule of Beneficial
Construction: Study of Judicial Decisions in India”

NATIONAL LAW INSTITUTE UNIVERSITY,

BHOPAL

Submitted by:
Yasha Shrivastava
BALLB (Hons.)- 10th Trimester
Roll No. 2013BALLB79
 Acknowledgement

It is indeed a great pleasure and a matter of immense satisfaction for me to express my deep
sense profound gratitude towards all the people who have helped and inspired me in this
project work.

First, I would like to give my gratitude to Prof. DebashreeSarkar for the efforts by her right
from the selection of the project to its completion. She spent her precious time whenever I
was in need of guidance.

Moreover, I would like to thank NLIU for providing opportunities and sources for learning
and eventual completion of this project.
 Table of Contents

 Abstract

 Introduction

 Principles/ Rules of Beneficial Construction

 Illustrations on the rule of Beneficial Construction

 Limitations on the application of the rule of Beneficial Construction

 Illustrations on the limitations of the rule of Beneficial Construction

 Illustrations from foreign Jurisdictions

 Conclusion

 References

 Abstract
 A general rule of interpretation is that if a word used in a statute excludes certain
cases from its common meaning, it should not be constrained unnecessarily to include
those cases.An exception to this rule is that when the objectives of the statute are not
met by excluding the cases, then the word may be interpreted extensively so as to
include those cases. However, when a word is ambiguous i.e. if it has multiple
meanings, which meaning should be understood by that word? This is the
predicament that is resolved by the principle of Beneficial Construction.
The following project aims to understand the concept of beneficial interpretation in
case of welfare legislations in the light of decided cases and it also lists out the
limitations imposed over judiciary while interpreting a statute, where beneficial
construction is required. The courts while interpreting such legislations have always
stressed on the doctrine of social justice and interpreted such legislations very
liberally.

 Introduction
 A beneficial statute has to be construed in its correct perspective so as to fructify the
legislative intent. When there are two or more possible ways of interpreting a section
or a word, the meaning which gives relief and protects the benefits which are
purported to be given by the legislation, should be chosen.

-Transport Corporation of India v. Employees State Insurance Corporation1

A beneficial legislation is a statute which purports to confer a benefit on individuals or

a class of persons. The nature of such benefit is to relieve said persons of onerous
obligations under contracts entered into by them. Further individuals with whom they
stand in certain relations may attempt to perpetrate oppressive acts upon the
vulnerable party and a beneficial legislation tends to protect them in such
instances.2When a statute is interpreted liberally and is given the widest possible
meaning which the language permits it is known as Beneficial Interpretation. When a
statute is meant for the benefit of a particular class and if a word in the statute is
capable of two meanings i.e. one which would preserve the benefits and one which
would not, then the meaning that preserves the benefit must be adopted. 3 Beneficial
construction is an interpretation to secure remedy to the victim who is unjustly denied
of relief. The interpretation of a statue should be done in such a way that mischief is
suppressed and remedy is advanced.4

In interpreting a beneficial statute, the principle established is that there is no room for
a narrower view5 but that the court is entitled to be generous towards the person on
whom the benefit has been conferred.6 It is the duty of the court to interpret a
provision, especially a beneficial one, liberally so as to give it a wider meaning rather
than a restrictive meaning which would negate the very object of the rule.7

It is a well settled canon of interpretation that in construing the provision of

beneficent enactments, the court should adopt that construction which advances,

1 (2000)1 SCC 426

2M.N Rao, N S Bindra’s Interpretation of Statutes, pg. 341(10th ed, 2007), Lexis NexisButterworths,NewDelhi
3Hanumant, On Beneficial Construction available at http://hanumant.com/IOS-Unit7-
BeneficialAndStrictConstruction.html.
4G. Granville Sharp, Maxwell on interpretation of statutes, pg 68 (10th ed. 1953),Sweet& Maxwell Limited,
London.

5Modern Movies v. SB Tiwari(1966) 1 Lab LJ 763

6ChotilalSowcar v. Jawantraj AIR 1966 Mad 322
7Madan Singh Shekhawat v. Union of India &Ors. (1998) 6 SCC 459
 fulfils, and furthers the object of the act rather than the one which would defeat the
same and render the protection illusory.8

The object of Industrial Disputes Act, 1947 is to improve the service conditions of
industrial labour so as to provide for them the ordinary amenities of life and by the
process, to bring about industrial peace which would in its turn, helps to improve the
conditions of labour. Therefore, the provisions of the Act have to be interpreted in a
manner which advances the object of the legislature contemplated in the objects and
reasons. Therefore a beneficial piece of legislation has to be construed in its correct
perspective so as to fructify the legislative intent underlying its enactment. When two
views are possible on its applicability to a given set of employees, that view which
furthers the legislative intent should be preferred to the one which would frustrate it. 9
This rule of liberal construction only be resorted to without doing any violence to the
language of the statute. It is also well-settled that a beneficent provision must be
meaningfully construed, so as to advance the object of the act, without causing any
lacuna or defect appearing in the same. 10 Also, Statutes like Minimum wages act 1948
should be given a beneficent interpretation because such acts are meant for the
welfare of the masses.11

However it is to be noted thatalthough beneficial legislation do receive liberal

interpretation, the courts try to remain within the scheme and not extend the benefit to
those not covered by the scheme.12 It is also true that once the provision envisages the
conferment of benefit limited in point of time and subject to the fulfilment of certain
conditions, their non-compliance will have the effect of nullifying the
benefit.13Further, the rule of interpretation can only be resorted to without doing any
violence to the language of the statute.14 In case of any exception when the
implementation of the beneficent act is restricted the Court would construe it narrowly
so as not to unduly expand the area or scope of exception. 15 The liberal construction
can only flow from the language of the act and there cannot be placing of unnatural

8ChinnamarKathian alias MuthuGounder v. Ayyavoo alias PerianaGounder AIR 1982 SC

9Transport Corporation of India v. Employees State Insurance Corporation (2000)1 SCC 426
10BaldeoSahai v. RC Bhasin AIR 1982 SC 1094
11Asanol Bus Assn v. Asst Labour Commr AIR 1967 Cal 371
12HarSharanVarma v State of Uttar Pradesh AIR 1985 SC 378
13Noor Hussain&Anr v Financial Commr AIR 1995 J&K 102
14Transport Corpn of India v Employees’ State Insurance Corpn&Anr (200) 1 SCC 426
15ShaikhGulfan v Sanatkumar, AIR 1965 SC 1839
 interpretation on the words contained in the enactment. Also, beneficial construction
does not permit raising of any presumption that protection of widest amplitude must
be deemed to have been conferred on those for whose benefit the legislation may have
been enacted.16

 Beneficial Construction – A tendency rather than a rule

It is said by Maxwell, that Beneficial Construction is a tendency and not a rule. The
reason is that this principle is based on human tendency to be fair, accommodating,
and just. Instead of restricting the people from getting the benefit of the statute, Court
tends to include as many classes as it can while remaining faithful to the wordings of
the statute. For example, in the case of Alembic Chemical Works v Workman, an
industrial tribunal awarded more number of paid leaves to the workers than what
Section 79(1) of Factories Act recommended. This was challenged by the appellant.
SC held that the enactment being welfare legislation for the workers, it had to be
beneficially constructed in the favour of worker and thus, if the words are capable of
two meanings, the one that gives benefit to the workers must be used.

When a statute is meant for the benefit of a specific class, and if a word in the statute
is capable of two meanings, one which would preserve the benefits and one which
would not, then the meaning that would preserve the benefits must be adopted and
shall be followed by the court of law. It is important to note that omissions will not be
supplied by the court. Only when multiple meanings are possible, can the court shall
pick the beneficial one. Thus, where the court has to choose between a wider mean
that carries out the objective of the legislature better and a narrow meaning, then it
usually chooses the former meaning carrying out the objective of the legislation.
Similarly, when the language used by the legislature fails to achieve the objective of a
statute, an extended meaning could be given to it to achieve that objective, if the
language is fairly susceptible to the extended meaning.

 Principles/ Rules for Beneficial Construction of legislations

16ESIC v MM Suri and Associates Ltd JT 1998 (7) SC 336

 Beneficial construction means an interpretation to promote public good and prevent
misuse of power. Beneficial provisions are added for general betterment in
social interest. The Courts should adopt constructive approach so as not to
exclude such provisions.
-Gauri Shankar Gaur v. State of U.P (1994)1 SCC 92

In order to interpret a statute beneficially three important principles should be

followed:-

 Words in the statute should be interpreted in its widest form but only to the extent
which the language permits or contains.

 The most complete remedy which a particular provision intends should be given.

 A statute should always purport to confer benefits on particular class or category for
which the beneficial legislation is intended.

In construing welfare legislation following steps should be adopted:-

 Liberal approach should be adopted

 Purposive construction which would effectuate the object of the welfare legislation
should be given to the expressions used in the statute.17

As welfare statues are aimed at protection and promotion of social and economic
well-being of its citizen they should be construed widely and liberally. Such statutes
should be interpreted in such a way that the power conferred by them is achieved and
benefits the particular class or category of people for whom it was intended by the
legislature.18Therefore it becomes the duty of the court to interpret a
provision,especially a welfare statute by giving it a wider meaning rather than a
restrictive meaning.

 Illustrative Cases on Beneficial Construction

17Nagpur District Central Co-operative Bank v. State of Maharashtra, 1987 Mah LJ 593
18G.P.Singh, Principle of Statutory Interpretation, (12 th ed.2010)
 The rule of beneficial construction could be better understood in the light of decided
cases.The primary rule for the application of the rule of beneficial construction is that,
there should be vagueness or ambiguity in the legislation which is capable to give two
meanings, one which serve the interest of a class of people and other which takes
away that interest. There are different kinds of legislations which receive beneficent
construction. Laws which are enacted with the object of promoting general welfare
and facing urgent social demands receive beneficial legislations. Examples of statutes
include The Factories Act, Industrial Disputes Act etc. In case of legislations which
may have two different interpretations, the legislation which favours the class of
persons for which it is purported should be preferred.

1. Pratap Singh v State of Jharkhand19

Facts:- In the instant case the provision of the Juvenile Justice Act, 1986 and the
provisions of Juvenile Justice (care and protection of children) act,2000 which
replaced the 1986 actcame up for consideration before a constitutional bench. The
question before the court was that, “whether the date of occurrence will be the
reckoning date for determining the age of alleged offender or the date when
he is produced before the court/competent authority.

Judgement: The main object of the act is to provide for the care, protection,
treatment, development andrehabilitation of neglected and delinquent juvenile. Since
the object behind the act is remedial in nature therefore beneficial construction should
be provided to promote beneficial object behind this act. Therefore the court held that
the reckoning date for determination of age of juvenile under both the acts is the date
of offence and not the date on which he is produced before thecourt.

2. B Shah v Presiding Officer, Labour Court20

Facts:In this landmark case of B Shah v Presiding Officer, Labour Court, court
applied beneficent rule of construction in construing section 5 of the Maternity
Benefit Act, 1961, which makes the employer liable to pay maternity benefit to
woman worker at the rate of average daily wage for the period of her actual absence
immediately preceding and including the day of her delivery and for six weeks
immediately following that day.

19(2005) 3 SCC 551

20AIR 1978 SC 12
 Judgement: The court took notice of the fact that the definition of ‘week’ was not
provided in the act. So it adhered to the dictionary meaning which says “ A cycle of 7
days”. The court applied the beneficial rule of construction and held that Sundays
must also be included. It computed the maternity benefit for the entire period of
absence as it is not intermittent period of 6 days excluding Sundays otherwise the
provision would have specified that. It also held that the Act was a beneficial piece of
legislation and was intended not only to subsist but also to make up for her dissipated
energy and taking care of her child.

3. Municipal Corporation of Delhi v. Female Workers(Muster Roll) 2 1

Facts:In the instant case the supreme court while dealing with the question as to,
whether the female worker working on muster roll should be given any maternity
benefit” interpreted article 42 of the Indian constitution along with article 11 of the
united nations convention on all forms of discrimination against women.

Held: The court held that the benefits under the Maternity Benefits Act 1961 shall be
provided to women (muster roll) employees of the corporation who are working under
the corporation on daily wages. The court also stated that it is a stale argument that,
maternity benefit act, 1961 can be extended only to workwomen in an “industry” and
not to the muster roll women employees of the municipal corporation. The court by
giving a wide interpretation to industry held that municipal corporation comes within
the ambit of Industry.

4. National Buildings Construction v. Pritam Singh Gill22

Facts:the Supreme Court was faced with the question whether the term workman
under Sec. 33C (2) of the Industrial Disputes Act would include such workmen who
were dismissed prior to the date of application under Sec. 33C (2). It was argued by
the Appellants that after his dismissal, the respondent had ceased to be a workman and
therefore had no locus to approach the Labour Court under Sec. 33C (2).
Judgement: The court rejected the argument and held that the primary purpose of the
section being to provide the aggrieved workman with a form similar to the executing
courts, it calls for a broad and beneficial construction consistently with other
21(2000) 3SCC 224
22AIR 1972 SC 1579
 provisions of the Act, whichshould serve to advance the remedy and to suppress the
mischief.23The Court accepted the argument of the Respondent that simply because
the respondent had been dismissed before he could apply to the Labour Court under
Sec. 33C (2) would not deprive him of the status of being a workman under Sec. 33C
(2).24
Thus, the Supreme Court gave a beneficial construction to the term workman under
the Industrial Disputes Act for the purpose of Section 33C in order to ensure that
dismissed workmen were not deprived of the locus to approach the Labour Court
under that Section.

5. Baldev Sahai v. R.C Bhaisn25

Facts: In the instant case the tenant was living with his siblings and mother. After he
left for Canada, leaving behind his mother and brother he kept paying the rent every
month on time. The suit for eviction under section 14(1) of the Delhi Rent Control Act
was filed against him due to ‘non- residence of tenant’ since mother and brother could
not be treated as family.

Judgement: The court observed that the word ‘ Family’ must be given a wider
meaning to include not only the head of the family but all the members or descendants
from the common ancestors actually living with the same head of the family. The
court therefore held that it is a beneficial legislation thus it should be meaningfully
and liberally construed so to advance the object of the act.

6. U. Unchoyi v. State of Kerala26

Facts: In the instant case the issue was that under the Minimum Wages Act, 1948, the
term ‘Minimum Wages’ is not defined. Thus, it is violative of Article 19(1)(g) of the
Constitution because it does not take into account the employer’s capacity to pay.
Judgement: The court held that since the act is a beneficial legislation. The basic
purpose of the act is to confer benefit on the workers and prevent the workers from
working for starvation wages. Hence the rule of beneficial construction has to be
applied and the legislation should be construed in the favour of the workers. Thus, the
legislation cannot be said to be violative of Article 19(1)(g).

23Ibid
24ibid
25AIR 1982 SC 1094
261962 SCR (1) 1946
 7. Mugnilal v. Sugan Chand27

Facts: In the instant case the issue arose in relation to Section 4(a) of the M.P
Accommodation Control Act, 1955. The section stated “…. that the tenant has failed
to make payment to the landlord of any arrears of rent within one month of the service
upon him of a written notice of demand.” The tenant in the present case failed to make
payment within one month of the demand.

Held: The condition under section 4(a) of the act was satisfied and that the clause did
not require that the non-payment should continue till the date of the suit.
The court has to look into the true spirit and object of the act, especially when it is a
beneficial legislation. For such statutes, the court ordinarily gives liberal interpretation
to prevent arbitrary executive action. But only because the legislation is beneficial,
that by itself cannot be extended to a situation which the statute does not contemplate.

8. Noor SabaKhatoon v. Mohd. Quasim28

Facts: In the instant case Section 125 CrPc 1973 and Sec 3(b) of Muslim Women’s
Protection of rights on Divorce Act, 1986 were construed by the court. Section 125
CrPc provided the rights of maintenance of Wife, Children and parents, whereas
section 3(b) of Muslim Women’s Protection of rights on Divorce Act, 1986 entitled a
Muslim women to claim maintenance from her husband for her minor children up to
the age of 2 years only.

Judgement:The court held that the effect of a beneficial legislation should not be
construed to be defeated by subsequent legislation except through a clear
provision. The rights of minor children to get maintenance from their father as
provided in Section 125 of CrPC was construed not to have been taken away in
respect of Muslims by the Muslim Women (Protection of Rights on Divorce) Act,
1986 section 3(b) which enabled a Muslim woman to claim maintenance for the
minor children upto the age of two years only from her former husband. It was held
by the court that the right of children to claim maintenance under CrPC was
independent of right of divorced mother to claim maintenance for the infant children
and former is not affected by 1986 Act.

9. Union of India v. Prabhakaran Vijay Kumar29

271964 SCR (5) 239
28AIR 1987 SC 3280
29(2008) 9 SCC 527
 Facts: In the instant case liberal interpretation was given to section 123( c) of the
Railways Act, which defines “ untoward accident”. The question before the court was
whether the expression “untoward accident” so defined in the act will also cover the
case of a passenger who fell down and died while trying to board the train and his
dependent would be entitled to compensation under section 124(a) of the Act.

Judgement: Justice Markendey Katju, held that, “no doubt it is possible that two
interpretations can be given to the expression “accidental falling of passenger from a
train carrying passenger”. The first being that it only applies when a person has
actually got inside the train and thereafter falls down from the train, while the second
being that it includes a situation where a person is trying to board the train and falls
down while trying to do so. Since the provision for compensation in the Railway Act
is a beneficial piece of legislation, in our opinion it should receive a liberal and wide
interpretation and not narrow and technical one. Hence in our opinion the latter of the
above mentioned two interpretations i.e the one which advances the object of the
statute and serves its purpose should be preferred.

10. State of Karnataka v. Vishwabharti Housebuilding Coop' Society & Others30

Facts: In the instant case the question before the Supreme court was regarding the
interpretation of Section 25 of Consumer & Protection Act, 1986. State of Karnataka
filed a cross- appeal challenging the section 25 of the Act by the high court as baring
the district forum from executing its own order.

Judgement:The Supreme Court held that in case of a social benefit oriented

legislation like the Consumer Protection Act, 1986 the provisions are to be construed
as broadly as possible in the favour of the consumer to achieve the purpose of the
enactment but without doing violence to the language. The court on the interpretation
of section 25 of the act stated that- Section 25 on a plain reading goes to show that the
provision contained therein presupposes that the forum or commission would be
entitled to execute its order. It however may send the matter for its execution only in
the event it is unable to do so. Such a contingency may arise only in a given situation
but in our given considered opinion the same does not lead to the conclusion that the

30(2003) 2 SCC 412

 consumer court cannot execute its own order for execution to the civil courts. Such
construction in our opinion would violate the plain language used therein and thus
must be held be untenable.

11. Sant Ram v Rajinderlal31

In this case the Supreme Court said that welfare legislation must be interpreted in a
third World perspective favouring the weaker and poor class. It has also been laid
down in the case of labour legislation that courts should not stick to grammatical
constructions but also have regard to ‘teleological purpose and protective intendment
of the legislation. Interpretation of labour legislations should be done by the courts
with more concern with the colour, the context and the content of the statute rather
than its literal import.

 Limitations on the Application of Beneficial Construction

If on the application of the rule of beneficial construction, the court finds that it is
doing complete justice and delivering a fair judgment then there is no question of why
should not such rule is applied. But there are certain restrictions which the court has to
take care of which at the time of application have to be adhered to –

1) Where the courts find that by the application of the rule of beneficial construction, it
would be re-legislating a provision of statute either by substituting, adding or altering
any provision of the act.

31AIR 1978 SC 1601

 2) Where any word in a statute confers to a single meaning only. Then the courts should
refrain from applying the rule of benevolent construction to the statute.

3) When there is no ambiguity in a provision of a statute so construed. If the provision is

plain, unambiguous and does not give rise to any doubt, the rule of beneficial
construction cannot be applied.

 Illustrations on the Limitations of Beneficial Construction

It is important to note that the principle of beneficial construction has to be applied

with a few safeguards. It can only be applied without “rewriting or doing violence to
the enactment”. When the language is clear and explicit, it leaves little scope for any
bending of interpretation.32 Sympathy cannot be a sole principle guiding
interpretation.33

1. Western India Plywood Ltd. v P Ashokan34

Facts:In the instant case the Employess State Insurance Act 1948, Section 53
provided that an insured person or his dependents will not be entitled to ‘any
compensation or damages’ under the Workmen’s Compensation Act 1923 or any other
law for the time being in force or otherwise in respect of an employment injury.

32Steel Authority of India Ltd, National Union Water Front Workers AIR 2001 SC 3527
33MarutiUdyog Ltd. v Remlap (2005) 2 SCC 638
34AIR 1997 SC 3883
 Judgement: This was held to bar even claim for compensation of damages in torts
although the Act is a beneficial legislation.

2. Mugnilal v. Sugan Chand35

Facts: In the instant case the issue arose in relation to Section 4(a) of the M.P
Accommodation Control Act, 1955. The section stated “…. that the tenant has failed
to make payment to the landlord of any arrears of rent within one month of the service
upon him of a written notice of demand.” The tenant in the present case failed to make
payment within one month of the demand.

Held: The condition under section 4(a) of the act was satisfied and that the clause did
not require that the non-payment should continue till the date of the suit.
The court has to look into the true spirit and object of the act, especially when it is a
beneficial legislation. For such statutes, the court ordinarily gives liberal interpretation
to prevent arbitrary executive action. But only because the legislation is beneficial,
that by itself cannot be extended to a situation which the statute does not contemplate.

3. Secretary State of Karnataka v Umadevi36

Facts: In this case the question before the Supreme Court was that whether those
employed on daily wages temporarily or on contractual basis by State or its
instrumentalities can be said to be holders of a post and have any right to
regularization under the act?

Judgement: the Supreme court held that those employed on daily wages temporarily
or on contractual basis by State or its instrumentalities cannot be said to be holders of
a post and have no right to regularization even when they have worked for a number
of years. This decision shows that sympathy or sentiment cannot be the sole ground
for passing a favourable order when there is no legal right to support such an order.

4. Nasiruddin v Sita Ram37

The Control of Rent and Eviction Acts seek to protect tenants from unjust evictions
and it is a principle that in case of doubt, such Acts should be interpreted to lean in
favour of tenants. However, it is a restriction that the benefit conferred on the tenants

351964 SCR (5) 239

36(2006) 4 SCC 1
37(2003) 2 SCC 577
 under these Acts can only be enjoyed on strict compliance of statutory provisions
contained in them.

5. A. Sundarambal v. Government of Goa, Daman and Diu38

Facts: In the instant case it was urged by the Appellant for the Court to declare a
school teacher to be a ‘workman’ under the Industrial Disputes Act.

Judgement: the Supreme Court took into account the words in the definition “to do
any skilled or unskilled manual, supervisory, technical or clerical work” (Sec. 2 (s))
and held that since a teacher would not fall into any of these categories, a teacher
could not be held to be a workman under the Act.The beneficial legislation should not
be construed such that it brings within its ambit a benefit which was not contemplated
by legislature.

 Illustrations from foreign Jurisdiction

 In Australia, the Aboriginal Land Rights Act, 1983 was enacted to give important
rights to the representatives of the Aboriginal people. Justice Kirby reiterated the
principle that the act should be given the most beneficial operation compatible with
the language. Further, he stated that any ambiguity should be resolved in favour of
Aboriginal people and any attempt by Parliament to restrict those rights must be plain
and clear.39

 In a similar case of anti-discrimination legislation, Grescher and Norman have held

that the way in which a judge should read a human rights statute should ‘stand apart
from and on higher ground’ than other canons and principles.40

 In the case of British Coal Corporation v King41, Lord Sankey approached the act to
beneficially construct it. He held that, “In interpreting a constituent or organic statue

3823 AIR 1988 SC 1700

39Minister Administering the Crown Lands Act v NSW Aboriginal Land Council (2008) 82 ALJR 1505
40Donna Greschner and Ken Norman 63 Can Bar Rev (1985) 805, 808-809
41British Coal Corporation v the King [1935] AC 500
 such as the Act, construction most beneficial to the widest amplitude possible
amplitude of its powers must be adopted.”

 In the United States, in the case of Huntington v Attrill42, the Supreme Court said that
whether a statute is remedial or penal ‘depends upon the question whether its purpose
is to punish the offense against the public justice of the state, or to afford a private
remedy to a person injured by the wrongful act’. Liberal construction has been
allowed in cases relating to providing, regulating worker benefits, antitrust, securities,
and unfair competition legislation. The remedial purpose canon is also found in
cases interpreting legislation designed to protect and promote public health and safety.
The canon has also been used to further social well-being of general public by
protecting individuals against race, gender, and age and disability discrimination.43

 Conclusion
In line with the settled canons of construction, Courts must adopt that construction
which advances the objects of the Statute in place of one that would defeat it.
Beneficial legislation should be interpreted in the widest form and hence should be
interpreted liberally.The welfare statutes and acts are aimed at improving the
economic and social conditions of its people. Thus these statutes should be interpreted
in such a manner that it fulfils the object and purpose of the statute.

As discussed above the case Sant Ram v Rajinderlal the Supreme Court said that
welfare legislation must be interpreted in a third World perspective favouring the
weaker and poor class. It has also been laid down in the case of labour legislation that
courts should not stick to grammatical constructions but also have regard to
‘teleological purpose and protective intendment of the legislation. Interpretation of

42Huntington v Attrill 146 US 657, 673-74 (1892)

43Chrisom v Roemer 501 U.S. 380,403 (1991); Dennis v Higgins 498 US 439,443 (1991)
 labour legislations should be done by the courts with more concern with the colour,
the context and the content of the statute rather than its literal import.

Thus, the courts must be vigilant to ensure that benefits conferred by welfare
legislation must not be defeated by subtle devices. It is duty of the court to get behind
the smoke screen and discover the true state of affairs. It can go behind the form and
see the substance of the transaction.

The strict and narrow jacket concept of law is no longer available for the purpose of
interpreting a social welfare piece of legislation especially after the new millennium.
The policy of a democratic Government should run in conjunction with the dynamic
interpretation offered by the courts. The courts exist for the society and in the event
the courts feel the requirement in accordance with principles of justice, equity and
good conscience, courts must rise up to the occasion to do complete justice and meet
expectation of the people.

 References
1. Study Material
2. G.P Singh
3. http://www.lawctopus.com/academike/beneficent-statutes-beneficent-rules-of-
construction/
4. http://www.legalservicesindia.com/article/article/harmonious-and-beneficial-
construction-as-rules-of-interpretation-1945-1.html
5. https://www.scribd.com/doc/308341613/Beneficial-Construction-of-Statues
6. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2298771