Supreme Court Annual Digest 2022- Interpretation of Statutes

Interpretation of Statute - Taxation Statutes - Exemption Notifications - The exemption notification should not be liberally construed and beneficiary must fall within the ambit of the exemption and fulfill the conditions thereof. In case such conditions are not fulfilled, the issue of application of the notification does not arise at all by implication - The notification has to be read as a whole. An exception and/or an exempting provision in a taxing statute should be construed strictly and given a meaning according to legislative intendment - It is not open to the court to ignore the conditions prescribed in the relevant policy and the exemption notifications issued in that regard.The Statutory provisions providing for exemption have to be interpreted in light of the words employed in them and there cannot be any addition or subtraction from the statutory provisions. (Para 8.1 - 8.3) Krishi Upaj Mandi Samiti v. Commissioner, 2022 LiveLaw (SC) 203 : AIR 2022 SC 1234 : (2022) 5 SCC 62

Interpretation of Statutes - “Ut Res Magis Valeat Quam Pereat” - A liberal construction should be put up on written instruments, so as to uphold them, if possible, and carry into effect, the intention of the parties - Interpretation of a provision of law that will defeat the very intention of the legislature must be shunned in favour of an interpretation that will promote the object sought to be achieved through the legislation. (Para 13) State of Madhya Pradesh v. Jogendra, 2022 LiveLaw (SC) 37 : AIR 2022 SC 933 : (2022) 5 SCC 401

Interpretation of Statutes - A government cannot misuse the "removal of difficulty clause" to remove all obstacles in its path which arise due to statutory restrictions. Allowing such actions would be antithetical to the rule of law. Misusing the limited power granted to make minor adaptations and peripheral adjustments in a statute for making its implementation effective, to side-step the provisions of the statute altogether would defeat the purpose of the legislation - Where there is a specific provision, it is not open to the State government to conjure up a lacunae or omission and purportedly exercise the power to remove difficulties. (Para 48- 49) State of West Bengal v. Anindya Sundar Das, 2022 LiveLaw (SC) 831 : AIR 2022 SC 4902

Interpretation of Statutes - A rule made under a statute could not override or supersede a provision of the parent statute itself. (Para 7) Union of India v. Alapan Bandyopadhyay, 2022 LiveLaw (SC) 12 : AIR 2022 SC 499 : (2022) 3 SCC 133

Interpretation of Statutes - A statute must be read to avoid a construction which would make certain provisions or terms meaningless or redundant. (Para 41) State of West Bengal v. Anindya Sundar Das, 2022 LiveLaw (SC) 831 : AIR 2022 SC 4902

Interpretation of Statutes - All interpretations must subserve and help implementation of the intention of the Act - This is applicable while interpreting any provision in any statute especially when the power under that provision is conferred to pass orders that may be just or proper. (Para 18) Bhola Kumhar v. State of Chhattisgarh, 2022 LiveLaw (SC) 589

Interpretation of Statutes - All the provisions in the Statute have to be construed in context with each other and no provision can be read in isolation - The provisions of a statue ought to be interpreted in such a manner which would advance the object and purpose of the enactment. (Para 39-41) Kotak Mahindra Bank ltd. v. A. Balakrishna, 2022 LiveLaw (SC) 534 : AIR 2022 SC 2652 : (2022) 9 SCC 186

Interpretation of Statutes - Courts would not indulge in interpretation of a report of a body and when there is better material in the form of the Act itself available for interpretation. (Para 18) New Delhi Municipal Council v. Minosha India Ltd., 2022 LiveLaw (SC) 469 : (2022) 8 SCC 384

Interpretation of Statutes - Each and every word and each and every phrase mentioned in the provision will have to be given effect to. Statutes have to be construed so that every word has a place and everything is in its place. (Para 21) Delhi Airport Metro Express Pvt. Ltd. v. Delhi Metro Rail Corporation, 2022 LiveLaw (SC) 452 : AIR 2022 SC 2165 : (2022) 9 SCC 286

Interpretation of Statutes - Environment and Forest Laws - The approach of the court in interpreting the laws relating to forests and the environment discussed (Para 25) Narinder Singh v. Divesh Bhutani, 2022 LiveLaw (SC) 620 : AIR 2022 SC 3479

Interpretation of Statutes - First and foremost principle of interpretation of a statute is the rule of literal interpretation - Purposive interpretation can only be resorted to when the plain words of a statute are ambiguous or if construed literally, the provision would nullify the object of the statute or otherwise lead to an absurd result. (Para 65 - 69) Vidarbha Industries Power Ltd. v. Axis Bank Ltd., 2022 LiveLaw (SC) 587 : (2022) 8 SCC 352

Interpretation of Statutes - Golden rule of interpretation discussed - If the words of a statute are not ambiguous, the scope of interpretation dwindles. (Para 19-23) New Delhi Municipal Council v. Minosha India Ltd., 2022 LiveLaw (SC) 469 : (2022) 8 SCC 384

Interpretation of Statutes - Heydon's/Mischief Rule. (Para 53) State of Himachal Pradesh v. Nirmal Kaur @ Nimmo, 2022 LiveLaw (SC) 866

Interpretation of Statutes - If a statute prescribes a method or modality for exercise of power, by necessary implication, the other methods of performance are not acceptable. (Para 13) Noor Mohammed v. Khurram Pasha, 2022 LiveLaw (SC) 652 : AIR 2022 SC 3592 : (2022) 9 SCC 23

Interpretation of Statutes - If the language is unambiguous and capable of one meaning, that alone should be applied and not any other, based under surmise that the Parliament or the legislature intended it to be so. In other words, it is only in cases of ambiguity that the court can use other aids to discern the true meaning. Where the statute is clear and the words plain, the legislation has to be given effect in its own terms - It is only when the application of literal interpretation gives rise to an absurdity, should the interpretation be expansive. (Para 52-54) New Noble Educational Society v. Chief Commissioner of Income Tax 1,2022 LiveLaw (SC) 859 : 2022 (15) Scale 302

Interpretation of Statutes - If the plain meaning of the provision does not admit of any ambiguity no other external aid will be necessary to interpret the provision except to give it the plain meaning. (Para 9) Delhi Airtech Services Pvt. Ltd v. State of U.P., 2022 LiveLaw (SC) 888

Interpretation of Statutes - Intention of legislature - Legislative intent in the enactment of a statute is to be gathered from the express words used in the statue unless the plain words literally construed give rise to absurd results. This Court has to go by the plain words of the statute to construe the legislative. (Para 11) State of Rajasthan v. Tejmal Choudhary, 2022 LiveLaw (SC) 158

Interpretation of Statutes - Interpretation of law has two essential purposes: one is to clarify to the people governed by it, the meaning of the letter of the law; the other is to shed light and give shape to the intent of the law maker. And, in this process the courts' responsibility lies in discerning the social purpose which the specific provision subserves. (Para 34) Apex Laboratories Pvt. Ltd. v. Deputy Commissioner, 2022 LiveLaw (SC) 195 : (2022) 7 SCC 98

Interpretation of Statutes - It is a settled principle of law that all the provisions in the statute have to be read harmoniously. It is presumed that each and every provision has been brought by the legislature into the statute book with some purpose. A particular provision cannot be read in isolation and has to be read in context to each other. An attempt has to be made to reconcile all the provisions of the statute together, unless it is impossible. (Para 40) Ardhendu Kumar Das v. State of Odisha, 2022 LiveLaw (SC) 539 : AIR 2022 SC 2695

Interpretation of Statutes - it is the duty of the court to avoid a head­-on clash between two sections of the Act and to construe the provisions which appear to be in conflict with each other in such a manner so as to harmonise them - when two conflicting provisions in an Act cannot be reconciled with each other, they should be so interpreted that, if possible, effect should be given to both - if the court has a choice between two interpretations, the narrower of which would fail to achieve the manifest purpose of the legislation, such an interpretation will have to be avoided - an interpretation, which will result in anomaly or absurdity, should be avoided - the statute has to be interpreted in such a manner that it preserves its workability. Kalyan Dombivali Municipal Corporation v. Sanjay Gajanan Gharat, 2022 LiveLaw (SC) 337 : AIR 2022 SC 1618

Interpretation of Statutes - it is the duty of the court to avoid a head­-on clash between two sections of the Act and to construe the provisions which appear to be in conflict with each other in such a manner so as to harmonise them - when two conflicting provisions in an Act cannot be reconciled with each other, they should be so interpreted that, if possible, effect should be given to both - if the court has a choice between two interpretations, the narrower of which would fail to achieve the manifest purpose of the legislation, such an interpretation will have to be avoided - an interpretation, which will result in anomaly or absurdity, should be avoided - the statute has to be interpreted in such a manner that it preserves its workability. Kalyan Dombivali Municipal Corporation v. Sanjay Gajanan Gharat, 2022 LiveLaw (SC) 337 : AIR 2022 SC 1618

Interpretation of Statutes - Legal Fiction - Legal fiction presupposes the existence of the State of facts which may not exist and then works out the consequences which flow from that state of facts. (Para 26) Gujarat State Civil Supplies Corporation v. Mahakali Foods Pvt. Ltd., 2022 LiveLaw (SC) 893 : AIR 2022 SC 5545

Interpretation of Statutes - Legal Fiction - When a legal fiction is employed by the legislature, it becomes a duty of the Court to interpret it and to give it meaning. In gleaning its meaning, the Court is duty bound to ascertain the purpose of this legislative device. The Court cannot allow its mind to be boggled in the matter of carrying the legal fiction to its logical end. But this is not the same as holding that the Court will not look to the object of the Act and, in particular, the fiction in question. (Para 36) New Okhla Industrial Development Authority (Noida) v. Yunus, 2022 LiveLaw (SC) 123 : AIR 2022 SC 847 : (2022) 9 SCC 516

Interpretation of Statutes - Maharashtra Control of Organised Crime Act, 1999 - the provisions of MCOCA need to be strictly construed and for their application, an unlawful activity has to fall within the periphery of organised crime. (Para 12-12.3) Abhishek v. State of Maharashtra, 2022 LiveLaw (SC) 516 : AIR 2022 SC 2488 : (2022) 8 SCC 282

Interpretation of Statutes - May and Shall - The expression "may", if circumstances so demand can be construed as "Shall". (Para 51) State Tax Officer v. Rainbow Papers Ltd., 2022 LiveLaw (SC) 743 : AIR 2022 SC 4141

Interpretation of Statutes - Meaning and intention of a statute must be collected from the plain and unambiguous expression used therein rather than from any notions which may be entertained by the court as to what is just and expedient - While interpretating a statute, if two interpretations are possible, the one which enhances the object of the Act should be preferred than the one which would frustrate the object of the Act. (Para 27) Gujarat State Civil Supplies Corporation v. Mahakali Foods Pvt. Ltd., 2022 LiveLaw (SC) 893 : AIR 2022 SC 5545

Interpretation of Statutes - Municipal laws giving effect to International Conventions - Courts of law must endeavor to maintain a uniformity of interpretation with courts of other jurisdictions while interpreting international treaties and conventions. (Para 29) Bhagwandas B. Ramchandani v. British Airways, 2022 LiveLaw (SC) 645

Interpretation of Statutes - Penal Statutes - The rule of strict construction of a penal statute or a special penal statute is not intended to put all the provisions in such a tight iron cast that they become practically unworkable, and thereby, the entire purpose of the law is defeated. (Para 12.4-12.6) Abhishek v. State of Maharashtra, 2022 LiveLaw (SC) 516 : AIR 2022 SC 2488 : (2022) 8 SCC 282

Interpretation of Statutes - Principles that govern the interpretation to be given to proviso in the context of main provision discussed. (Para 50) Prabha Tyagi v. Kamlesh Devi, 2022 LiveLaw (SC) 474 : AIR 2022 SC 2331

Interpretation of Statutes - Purposive Construction - A statute has to be construed according to the intent that makes it and it is always the duty of the Court to act upon the true intention of the legislature. If a statutory provision is open to more than one interpretation, it is always desirable of the Court to choose the interpretation which represents the true intention of the legislature. (Para 43-46) Securities and Exchange Board of India v. National Stock Exchange Members Association, 2022 LiveLaw (SC) 840 : AIR 2022 SC 5213

Interpretation of Statutes - Purposive Interpretation - While interpreting the provisions of the statute, the court has to prefer an interpretation which advances the purpose of the statute - Even in relation to a penal statute, any narrow and pedantic, literal and lexical construction may not always be given direct effect and the interpretation has to be preferred with regard to the subject matter of the offence and the object of law it seeks to achieve. (Para 66-80) State of Himachal Pradesh v. Nirmal Kaur @ Nimmo, 2022 LiveLaw (SC) 866

Interpretation of Statutes - Retrospectivity - A statute which affect substantive rights is presumed to be prospective in operation unless made retrospective and unless textually impossible a statute which merely affects procedure is presumed to be retrospective. However, a statute which not only changes the procedure but also creates new rights or liabilities is to be construed to be prospective in operation, unless otherwise provided either expressly or by necessary implication. State of Rajasthan v. Tejmal Choudhary, 2022 LiveLaw (SC) 158

Interpretation of Statutes - Retrospectivity - Every statute is prospective, unless it is expressly or by necessary implication made to have retrospective operation. There is a presumption against retrospectivity. An express provision should ordinarily be made to make a statute retrospective. The presumption against retrospectivity may also be rebutted by necessary implication. (Para 7) State of Rajasthan v. Tejmal Choudhary, 2022 LiveLaw (SC) 158

Interpretation of Statutes - Retrospectivity - The device of a legal fiction can also be used to introduce retrospective operation. Generally, it is considered that every statute dealing with substantive rights is prima facie prospective unless it is expressly or by necessary implication made retrospective. State of Rajasthan v. Tejmal Choudhary, 2022 LiveLaw (SC) 158

Interpretation of Statutes - Rule of Contra proferentem - The rule of contra proferentem thus protects the insured from the vagaries of an unfavourable interpretation of an ambiguous term to which it did not agree - The rule assumes special significance in standard form insurance policies, called contract d' adhesion or boilerplate contracts, in which the insured has little to no countervailing bargaining power. Haris Marine Products v. Export Credit Guarantee Corporation (ECGC), 2022 LiveLaw (SC) 432 : AIR 2022 SC 3036

Interpretation of Statutes - Same expression appearing at different places in a statute - it is the context which must determine whether the same expression occurring at two different places must be considered differently or in the same light. (Para 49- 50) State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 LiveLaw (SC) 20 : AIR 2022 SC 973

Interpretation of Statutes - Service Law - When the rules are specific and clear, there is no need for interpretation which may lead to a case of judicial legislation. (Para 13) Union of India v. Manpreet Singh Poonam, 2022 LiveLaw (SC) 254 : (2022) 6 SCC 105

Interpretation of Statutes - Strict Interpretation - Substantive law should be construed strictly so as to give effect and protection to the substantive rights unless the statute otherwise intends. Strict construction is one which limits the application of the statute by the words used - The basic rule of strict construction of a penal statute is that a person cannot be penalised without a clear letter of the law. Presumptions or assumptions have no role in the interpretation of penal statutes - They are to be construed strictly in accordance with the provisions of law. Nothing can be implied. In such cases, the courts are not so much concerned with what might possibly have been intended. Instead, they are concerned with what has actually been said. (Para 46-47) State of Gujarat v. Sandip Omprakash Gupta, 2022 LiveLaw (SC) 1031

Interpretation of Statutes - Subordinate Legislation - A subordinate legislation must be interpreted to effectuate the statutory purpose and objective. (Para 21.1) Regional Transport Authority v. Shaju, 2022 LiveLaw (SC) 174 : 2022 (3) SCALE 554

Interpretation of Statutes - Taxation - Exemption Entry - When the exemption Entry is clear and unambiguous, no external aid for interpretation is called for, whether in the form of Budget speech or any other notification under any other enactment. (Para 11) Authority for Clarification and Advance Ruling v. Aakavi Spinning Mills (P) Ltd., 2022 LiveLaw (SC) 191

Interpretation of Statutes - Taxation Laws - In a taxing statute the provisions are to be read as they are and they are to be literally construed, more particularly in a case of exemption sought by an assessee - An assessee claiming exemption has to strictly and literally comply with the exemption provisions. (Para 8, 11) Principal Commissioner of Income Tax-III Bangalore v. Wipro Ltd., 2022 LiveLaw (SC) 583 : AIR 2022 SC 3466

Interpretation of Statutes - Taxation Statutes - In the taxing statute, it is the plain language of the provision that has to be preferred, where language is plain and is capable of determining defined meaning. Strict interpretation to the provision is to be accorded to each case on hand. Purposive interpretation can be given only when there is an ambiguity in the statutory provision or it alleges to absurd results. (Para 14.3) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxation Statutes - The exemption notification should be strictly construed and given meaning according to legislative intendment. The Statutory provisions providing for exemption have to be interpreted in the light of the words employed in them and there cannot be any addition or subtraction from the statutory provisions. (Para 14.3) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxation Statutes - The notification has to be read as a whole. If any of the conditions laid down in the notification is not fulfilled, the party is not entitled to the benefit of that notification. An exception and/or an exempting provision in a taxing statute should be construed strictly and it is not open to the court to ignore the conditions prescribed in industrial policy and the exemption notifications. (Para 14.2) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxation Statutes - The principle that construction favourable to the assessee should be adopted shall not be applicable to construction of an exemption notification, if it is clear and not ambiguous. Thus, it will be for the assessee to show that he comes within the purview of the notification. Eligibility clause in relation to exemption notification must be given effect to as per the language and not to expand the scope deviating from the language. (Para 14.6) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxation Statutes - There is a vast difference and distinction between a charging provision in a fiscal statute and an exemption notification. (Para 14.6) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxation Statutes - While the exemption notification should be liberally construed, beneficiary must fall within the ambit of the exemption and fulfill the conditions thereof. In case such conditions are not fulfilled, the issue of application of the notification does not arise. (Para 14.1) State of Gujarat v. ArcelorMittal Nippon Steel, 2022 LiveLaw (SC) 79 : (2022) 6 SCC 459

Interpretation of Statutes - Taxing Statutes - Principle of interpretation of taxing statutes – that they need to be interpreted strictly – cannot sustain when it results in an absurdity contrary to the intentions of the Parliament. (Para 33) Apex Laboratories Pvt. Ltd. v. Deputy Commissioner, 2022 LiveLaw (SC) 195 : (2022) 7 SCC 98

Interpretation of Statutes - The construct of the provision must depend on the context of the legislative intent and the purpose for which such dispensation has been envisaged. The setting in which the expression has been used in the concerned section of the Act would assume significance. (Para 16) NKGSB Cooperative Bank Ltd. v. Subir Chakravarty, 2022 LiveLaw (SC) 212 : AIR 2022 SC 1325 : (2022) 10 SCC 286

Interpretation of Statutes - The Courts should refrain itself from expressing value judgments and policy views in order to interpret statutes. Statutes are to be read in their plain language and not otherwise. (Para 45) M.S.P.L. Ltd. v. State of Karnataka, 2022 LiveLaw (SC) 886

Interpretation of Statutes - The interpretation is to be in the manner which will subserve and promote the object and intention behind the legislation. If it is not interpreted in the manner as aforesaid it would defeat the very intention of the legislation (Para 14.3) Kerala State Beverages Manufacturing & Marketing Corporation Ltd. v. Assistant Commissioner of Income Tax Circle 1(1), 2022 LiveLaw (SC) 4 : AIR 2022 SC 309 : (2022) 4 SCC 240

Interpretation of Statutes - The interpretation which advances the object and purpose of the Act, has to be preferred. (Para 24) Chhattisgarh State Power Distribution Company Ltd. v. Chhattisgarh State Electricity Regulatory Commission, 2022 LiveLaw (SC) 478 : AIR 2022 SC 2904

Interpretation of Statutes - The object of a proviso is to except from the main provision something enacted in the substantive clause. It cannot however, by itself be read as a substantive provision - The scope of a proviso. (Para 55-58) New Noble Educational Society v. Chief Commissioner of Income Tax 1,2022 LiveLaw (SC) 859 : 2022 (15) Scale 302

Interpretation of Statutes - The words used in a particular statute cannot be used to interpret the same word in a different statute especially when the two statues are not pari materia with each other and have a wholly different scheme from one another. (Para 11) Board of Control for Cricket in India v. Regional Director Employees' State Insurance Corporation, 2022 LiveLaw (SC) 725

Interpretation of Statutes - To examine whether a provision is directory or mandatory, one of the tests is that the court is required to ascertain the real intention of the legislature by carefully attending to the whole scheme of the statute. (Para 29) Manickam @ Thandapani v. Vasantha, 2022 LiveLaw (SC) 395

Interpretation of Statutes - When a provision of a statute is made subject to another provision by the legislature, this evinces an intent that where the latter provision is attracted, the former would give way. (Para 43) State of Sikkim v. Jasbir Singh, 2022 LiveLaw (SC) 116 : (2022) 7 SCC 287

Interpretation of Statutes - When Statutes provide more than one judicial fora for effectuating a right or to enforce a duty-obligation, it is a feature of remedial choices offered by the State for an effective access to justice. Therefore, while interpreting statutes provisioning plurality of remedies, it is necessary for Courts to harmonise the provisions in a constructive manner. (Para 14.1-14.2) Experion Developers Pvt. Ltd. v. Sushma Ashok Shiroor, 2022 LiveLaw (SC) 352 : AIR 2022 SC 1824

Interpretation of Statutes - When the language of a statutory provision is plain and unambiguous, it is not permissible for the Court to add or subtract words to a statute or read something into it which is not there. It cannot rewrite or recast legislation. (Para 75) Kotak Mahindra Bank ltd. v. A. Balakrishna, 2022 LiveLaw (SC) 534 : AIR 2022 SC 2652 : (2022) 9 SCC 186

Interpretation of Statutes - When two or more enactments operating in the same field contain a non obstante clause stating that its provisions will have effect notwithstanding anything inconsistent therewith contained in any other law, the conflict has to be resolved upon consideration of the purpose and policy underlying the enactments - The rule that a non-obstante clause in a later statute prevails over the non-obstante clause in an earlier statute is not an absolute rule. The question of which provision prevails, would necessarily depend on the object of the enactment and, in particular, the object of giving overriding effect to the enactment or any specific provision thereof. (Para 68-70) Owners and Parties Interested in the Vessel M.V. Polaris Galaxy v. Banque Cantonale De Geneve, 2022 LiveLaw (SC) 793

Interpretation of Statutes - Where a statute contains both general provision as well as specific provision, the later must prevail. (Para 8) K.C. Laxmana v. K.C. Chandrappa Gowda, 2022 LiveLaw (SC) 381 : 2022 (6) SCALE 315

Interpretation of Statutes - Where the definition of a word is inclusive, as presaged by the adoption of the expression 'includes', it is prima facie extensive. (Para 32) State of Maharashtra v. 63 Moons Technologies Ltd; 2022 LiveLaw (SC) 400 : (2022) 9 SCC 457

Interpretation of Statutes - Where the same Statute uses different terms and expressions, then it is clear that Legislature is referring to distinct and different things. (Para 14.5) Kerala State Beverages Manufacturing & Marketing Corporation Ltd. v. Assistant Commissioner of Income Tax Circle 1(1), 2022 LiveLaw (SC) 4 : AIR 2022 SC 309 : (2022) 4 SCC 240

Interpretation of Statutes - While dealing with a welfare legislation, a purposive interpretation giving the benefit to the needy person being the intendment is the role required to be played by the court. (Para 57) Satender Kumar Antil v. Central Bureau of Investigation, 2022 LiveLaw (SC) 577 : AIR 2022 SC 3386 : (2022) 10 SCC 51

Interpretation of Statutes - While interpreting the provisions of a statute, it is necessary that the textual interpretation should be matched with the contextual one. The Act must be looked at as a whole and it must be discovered what each section, each clause, each phrase and each word is meant and designed to say as to fit into the scheme of the entire Act. No part of a statute and no word of a statute can be construed in isolation. Statutes have to be construed so that every word has a place and everything is in its place. (Para 61) Renaissance Hotel Holding Inc v. B. Vijaya Sai, 2022 LiveLaw (SC) 65 : (2022) 5 SCC 1

Interpretation of Statutes - Words of a taxing statute should be read in their ordinary, natural, and grammatical meaning - In construing the words in a constitutional enactment that confers legislative power, a liberal construction should be placed upon the words so that they may have effect in their widest amplitude. (Para 47) OCL India Ltd. v. State of Orissa, 2022 LiveLaw (SC) 911 : AIR 2022 SC 5609