Rule of Beneficial Construction
Rule of Beneficial Construction
When the literal meaning of the statute defeats the objective of the legislature, the court may depart from the dictionary and instead give it a meaning which will advance the remedy and suppress the mischief. This supports the initial and modern approach that is to effectuate the object and purpose of the act. The main objective by extending the meaning of the statute is to ensure that its initial purpose (public safety, maintenance of law and order) is justified. This rule looks into the reasons as per why the statute was initially enacted and promotes the remedial effects by suppressing the mischief. Though the rule almost covers the main grounds of the statute but cannot be applied to Fiscal statutes.
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. When a statute is meant for the benefit of a particular 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 preserves the benefit must be adopted. Omissions will not be supplied by the court, only when multiple meanings are possible, can the court 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. 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. This is evident in the case of B Shah v. Presiding Officer, AIR 1978, where Section 5 of Maternity Benefits Act, 1961 was is question, where an expectant mother could take 12 weeks of maternity leave on full salary. In this case, a woman who used to work 6 days a week was paid for only 6×12=72 days instead of 7×12=84 days.
SC held that the words 12 weeks were capable of two meanings and one meaning was beneficial to the woman. Since it is a beneficial legislation, the meaning that gives more benefit to the woman must be used.
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. Workmen AIR 1961, 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. The Supreme Court held that the enactment being a welfare legislation for the workers, 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.
Similarly, in U. Unichoyi v. State of Kerala, 1963, the question was whether setting of a minimum wage through Minimum Wages Act, 1948 is violative of Article 19(1)(g) of the Constitution because the Act did not define what is minimum wage and did not take into account the capacity of the employer to pay. It was held that the Act is a beneficial legislation and it must be construed in favour of the worker. In an under developed country where unemployment is rampant, it is possible that workers may become ready to work for extremely low wages but that should not happen.