Golden Rule of Interpretation

7. Golden Rule of Interpretation
This is also called 'Rule of Reasonable Construction'. The rule states that exclusive reliance on dictionary meaning or literal meaning may not indicate proper intention of legislature. Occasionally, literal meaning gives absurd or inconsistent results. In such cases, the statute should be construed so as to give sensible meaning that is rational and fair, for which, some violence to language and some modification in grammatical ~nd ordinary sense of the words may be done. (Gray Vs. Putron (1857) 6 H.L.-Old British case). When plain literal interpretation produces absurd result, which could never have been intended by Legislature, Court might modify the language or even do some violence to it, so as to achieve the obvious intention of the Legislature
and produce a rational construction-K. P. Varghese Vs. fTO-(1981) 131 ITR 597similar view in ClT Vs. J.H. Gotla AIR 1985 SC 1698.
Normally, it is not permissible to read words in statute which ,ue not there. However, if certain words in the statute become meaningless if such words are not supplied, it would be permissible to supply the words-Surjit Singh Kalra Vs. UOI-1991 (2) SCC 87.
In Tilkayat Shri Govindlalji V s. State of Rajasthan-AIR 1963 SC 1638, it was held that where two interpretations are possible, Court should adopt the construction which upholds validity of the Act rather than one which affects its validity.
While 'literal rule' is general rule in construing a statute, it should not be adopted if it leads to discriminatory or incongruous result. Where a literal interpretation leads to an absurd or unintended result, the language of the statute can be modified to accord with the intention of Parliament and to avoid absurdity-Co W.S. (India) Ltd. Vs. CfT (1994) 208 ITR 649 (sq.
In CCE Vs. Parle Exports (P.) Ltd.-AIR 1989 SC 644, it was observed that primacy is to be given to the text. However, regard shall be had to the words, context, subject-matter, effects and consequences, as well as spirit and reason of the law.
In an intuesting case, newspapers were excluded from the definition of 'goods' under CST Act by an amendment, obviously with intention to ensure that news papers, which are vital for democracy and freedom of speech, are not taxed. Under CST Act, raw materials can be purchased at concessional rates on submission of prescribed form if the raw materials are to be used for manufacture. Since 'newspapers' are excluded from definition of goods', obviously, the manufacturers of newspaper 'would not be able to purchase newsprint at concessional rate of Central Sales Tax, if the provision is applied mechanically. This was an unexpected result of the amendment to CST Act in definition of 'goods'. it is obvious that while granting exemption of CST to newspapers, Parliament would never have intended to penalise them by not allowing purchase of newsprint at concessional rate. it was held that while granting exemption to newspapers from Central Sales Tax, it was never intention of Parliament to create burden of levy of tax on the newspaper. Hence, it was held that the newspapers can buy newsprint at concessional rate-[Printers (Mysore) Ltd. Vs. Asst., CTO-IT 1994 (1) SC 692].
Subsidiary Rules of Interpretation
Various conventions and concepts have been developed over the years for interpretation of Statute, which can be termed as 'Subsidiary Rules for Interpretation'. These are summarised below.