Chambers of Ishaan Garg
Ch. No. 217, Western Wing, District & Sessions Court, Tis Hazari, New Delhi, Delhi 110054
+91 8851742417, +91 8800386163
Case - Kalpana Mehta v. Union of India, AIR 2018
Precedents followed - [R.S. Nayak v. A.R. Antulay 1984]
The Constitution Bench (kalpana) held that the Court can rely on a PSC Report as an ‘external aid’ for statutory interpretation. When the words of a statute are ambiguous, a PSC Report serves as an ‘external aid’ to interpret a statutory provision.
Use- PSC Report can be used to evaluate the historical background of a law, or the nature of the problem that a statute sought to cure (Mischief)
The Court also agreed with the conclusions of two earlier Constitution Bench decisions – in R.S. Nayak v. A.R. Antulay 1984 -and- State of Mysore v. R.V. Bidap 1974
In both these decisions, it was held that the reports and recommendations of Committees/Commissions which preceded the enactment of a statute can be used as ‘external aids’ to interpret the meaning of ambiguous words in a statutory provision. It was also clarified that such reports cannot be decisive, and the Court is free to arrive at a different conclusion.
These decisions also expressed disagreement with the approach adopted by British Courts – which had on many occasions taken a view that parliamentary materials are not legitimate tools of statutory interpretation. In Antulay’s case (1984) – the SC noted that across multiple jurisdictions, there was a growing trend of using committee reports as a tool for statutory interpretation, and even British Courts had begun reversing their earlier position.
