Mukt Shabd Journal ISSN NO : 2347-3150

GENERAL PRINCIPLES OF ALONG WITH SPECIAL REFERENCE TO MISCHIEF RULE AND OF INTERPRETRATION

*Upasana Borah Student N.E.F LAW COLLEGE AFFILIATED TO GAUHATI UNIVERSITY, ASSAM B.B.A LL.B (HONS)

ABSTRACT

Lawmaking body makes the law and court deciphers it at the hour of conveying equity. Understanding is the essential capacity of a court. At whatever point debate precedes the court and there is a vagueness about the genuine significance of the law, court deciphers the law. Translation implies giving best single importance of the words or expressions utilized in the law, The Golden Rule was characterized by Master Wens leydale in the Gray v Pearson case (1857) as: "The syntactic and standard feeling of the words is to be clung to except if that would prompt some ridiculousness or some repulsiveness or irregularity with the remainder of the instrument in which case the syntactic and normal feeling of the words might be adjusted in order to maintain a strategic distance from the idiocy and irregularity, however no farther." The Mischief Rule gives the most watchfulness to judges and is fit to explicit, frequently questionable cases. The standard permits resolutions to be refined and created. Nonetheless, the expanded job of the adjudicator implies that his perspectives and biases can impact the ultimate choice. The standard is expected to amend 'Mischief' in the rule and decipher the resolution fairly. The wickedness Rule employments -based law to decide how the resolution is deciphered.

Keywords: INTERPRETATION, GOLDEN RULE, MISCHIEF RULE, SUPREME COURT, EXTERNAL AIDS TO INTERPRETATION.

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1. INTRODUCTION

Governing body makes the law and court deciphers it at that point of conveying equity. Understanding is the essential capacity of a court. At whatever point question precedes the court and there is an equivocalness about the genuine importance of the law, court deciphers the law. Understanding methods giving best single which means of the words or expressions utilized in the law. Since the will of council is communicated in type of resolution. Resolution is the beginning stage in understanding. Resolution incorporates points of interest, for example, short title, long title, preface, minimal notes, headings of a gathering of areas or individual segments, meaning of understanding statements, stipulations, representations clarifications, plans, accentuations and so forth. Every single part communicated in the resolution is significant base for understanding. To decipher, court needs to peruse resolution as a entirety. The court isn't required to decipher self- assertively. What's more, have to follow certain standards those are referenced as broad rules that is strict importance, brilliant standard and naughtiness rule. Other than this court needs to think about Harmonious Rule also, the resolution ought to be perused all in all. There are inward what's more, outside guides for making understanding appropriately that is according to the aim of legislators at the hour of creation of law. Rules of translation give solid base to the super structure of legal thinking. Contemplated decisions very frequently need the consistent help of certain all around settled standards for the most part applied by judges to show up at persuading choices. The review of the Supreme Court decisions during the year 2013 demonstrated this reality. The assumption of legality of rule is extravagantly dissected, talked about and applied in different choices. Resort to abstract and purposive translation has likewise helped the court at fitting events. Inner guides of preface, titles, object statement, stipulation and so on., are likewise helpfully used. Outer guides for instance adage, books, reports, and so forth are additionally discovered valuable. Out of different choices which were examined in last overview two were alluded for higher seat as the adjudicators of division seat had contrast of feeling. It is a characteristic interest with regards to the ultimate result of these two decisions. The Supreme Court of India in the hunt of 'administrative goal' had talked about practically completely settled "dependable guidelines". Because of essence of tremendous number of cases the current review has abstained from studying high court decisions and bound just to some significant choices of the Supreme Court. Taking into

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account the authoritative blast and a responsive legal executive in India, challenges in regards to understanding need no uncommon clarification. A very work effectively repeats that "one point ought to be uncontroversial: understanding is comparative with the record being deciphered." Divergent translation of the court, in this way, is some time common. The Supreme Court, on account of State of Gujarat v. Hon' Ble Mr. Justice R.A. Mehta (Retd) be that as it may, began with repeating the admonition which it gave fifty years in a seven appointed authorities seat judgment. It extricated from The Keshav Factories Co. Ltd., Petlad v. The Commissioner of Income charge, Bombay North, Ahmedabad, where this court held: "When this Court chooses inquiries of law, its choices are, under Article 141, official on all Courts inside the region of India, thus, it must be the consistent undertaking and worry of this Court to present and keep up a component of conviction and coherence in the translation of law in the nation. Visit practice by this Court of its capacity to survey its previous choices on the ground that the view squeezed previously it later appears to the Court to be more sensible, may by chance will in general make law dubious and present disarray which must be reliably kept away from. It has been appropriately said that 'words are not inactive operators which means something very similar and conveying a similar incentive by any means times and in all unique circumstances.'

II. DECIPHERING THE RESOLUTIONS / INTERPRETING THE STATUTES The term legal understanding alludes to the activity of a court in attempting to comprehend and clarifying the importance of a bit of enactment. Numerous cases go to advance on a state of translation. In the first place, laws must be drafted when all is said in done terms and should bargain with both present and future circumstances. Frequently, a law which was drafted in light of one specific circumstance will in the end be applied to very various circumstances. Enactment is drawn up by sketchers, and an artist's ability to foresee what's to come is constrained. He may not predict some future chance, or ignore a potential confusion of the first expectations of the enactment. Another issue is enactment frequently attempts to manage issues that include unique and clashing interests. Both lawful and general English contain numerous words with more than one significance. With this being the situation, even the best drafted enactment can incorporate numerous ambiguities. This isn't the issue of the artist, basically an impression of the way that where individuals take a gander at a book from various perspectives they will normally find various implications in the language utilized. Judges in England for the

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most part apply three fundamental standards of legal translation, and comparative standards are likewise utilized in other custom-based law locales. The exacting principle, the brilliant rule and the naughtiness rule. Despite the fact that judges are not bound to apply these principles, they by and large take one of the accompanying three methodologies, and the methodology taken by any one specific appointed authority is regularly an impression of that judge's own reasoning.

Requirement For Interpretation 1. Intricacy of rules with respect to the idea of the subject, various artists and the mix of lawful and specialized language can bring about confusion, unclear and uncertain language. 2. Expectation of future occasions prompts the utilization of vague terms. The unimaginable undertaking of foreseeing each conceivable situation likewise prompts the utilization of vague language. Judges along these lines need to decipher resolutions as a result of the holes in law. Models of inderterminate language incorporate words, for example, "sensible". For this situation the courts are answerable for figuring out what comprises "sensible". 3. The multifaceted idea of language. Language, words also, phrases are a loose type of correspondence. Words can have various definitions and implications. Each gathering in court will use the definition and which means of the language generally profitable to their specific need. It is dependent upon the courts to choose the most right utilization of the language utilized.

III. RULES OF INTERPRETATION

I. Brilliant /Golden Rule of Interpretation Which means and Origin of Golden Rule ,The brilliant standard is that the expressions of a rule must prima facie be given their normal importance. It is one more guideline of development that when the expressions of the rule are clear, plain and unambiguous, at that point the courts will undoubtedly give impact to that significance, independent of the outcomes. It is said that the words themselves best pronounce the aim of the law-provider." The brilliant principle (likewise: the British guideline) is an exemption to the exacting guideline and will be utilized where the strict principle produces the outcome where

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Parliament's goal would be evaded as opposed to applied. The Golden Rule is First time Propounded in Gray v Pealson (1857), Lord Wensleygale stated: "The strict principle ought to be utilized first, however on the off chance that it brings about silliness, the syntactic and normal feeling of the words might be adjusted, in order to stay away from ludicrousness and irregularity, however no further." A few appointed authorities have recommended that a court may withdraw from the normal significance where that would prompt ludicrousness. In Gray v Pearson (1857) 6 HL Cas 61, Lord Wensleydale stated: the syntactic and standard feeling of the words is to be clung to, except if that would prompt some silliness, or some offensiveness or irregularity with the remainder of the instrument, in which case the syntactic and conventional feeling of the words might be adjusted, in order to maintain a strategic distance from that idiocy and irregularity, however no farther." This got known as "Ruler Wensleydale's brilliant guideline". It just applies where the words are uncertain.

R v Allen (1872) LR 1 CCR 367 The Law Commission (1969) noticed that 1. The standard gave no reasonable way to test the presence of the attributes of silliness, irregularity or burden, or to gauge their quality or degree. 2. As it appeared that "craziness" was practically speaking decided by reference to whether a specific translation was beyond reconciliation with the overall approach of the council "the brilliant guideline ends up being a less express type of the underhandedness rule".

UTILIZATION OF GOLDEN RULE

This arrangement of depending on outer sources, for example, the precedent-based law in deciding the genuine aim of the parliament is currently observed as a major aspect of the , although the strict methodology shares been prevailing practically speaking law frameworks for longer than a century, makes a decision about now give off an impression of being less limited by the dark stated purpose of the law and are all the more willing to attempt to decide the genuine expectation of the Parliament. The undertaking of the adjudicator is presently observed as being offer impact to the administrative motivation behind the rule being referred to. Just as these three standards of translation, there are various decides that are held to apply while deciding the significance of a rule:

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1. The rule is assumed not to tie the Crown 2. Rules don't work reflectively in regard to meaningful law (instead of procedural law) 3. They don't meddle with legitimate rights previously vested 4. They don't remove the locale of the courts They don't diminish established law or universal law Significance of Golden Rule of Interpretation. The brilliant/golden principle is an alteration of the strict standard and is utilized when the strict translation of words would prompt a 'show ridiculousness'. One case of the utilization of the brilliant standard is the situation of R v Allen – Defendant is accused of plural marriage, an offense precluded in Offenses Against Persons Act 1861 which peruses "whoever is hitched, weds another submits plural marriage." The court held that "weds" need not mean an agreement of marriage as it was unimaginable for a individual who is as of now wedded to go into another substantial agreement of marriage. Thus, the court deciphered it as "experiencing wedding function". The standard can be utilized in more than one way. It has two specific applications: a restricted methodology and a wide approach. The restricted methodology is utilized where the importance of the word which is being deciphered is questionable for example has more than one importance. The adjudicator at that point applies the importance which best suits the setting where the word is being deciphered. The main instances of R v Allen (1872) and Adler v George (1964) can most likely best delineate the utilization and use of the brilliant guideline. The term 'restricted methodology' is a reflection on certain appointed authorities sees on how the brilliant guideline ought to be utilized. It recommends that it is more constrained and limited than different guidelines, for example, the wickedness rule or purposive methodology. It was Lord Reid in Jones v DPP (1962) who helped us to remember the significance of making an effort not to give a significance to a word utilized in a resolution which goes past what is sensible. Another case of the court's ability to adjust a word or arrangement to maintain a strategic distance from a ludicrous outcome is the situation of Sigsworth (1935). A child had killed his mom and as the mother had not caused a will to the domain was to be dispersed to her closest relative under the Organization of Estates Act 1925. This implied her child would have acquired as her 'issue'. The court had an issue with this on open arrangement grounds, in that it was disgusting for a killer to profit by the executing. The court applied the brilliant standard in inclination to the strict guideline and deciphered the word 'issue' in order to reject somebody who had executed the expired. Case M. Pentiah Vs Veeramallappa: - The respondent were chosen individual from metropolitan advisory group under

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Hyderabad city and town board act 1951 which was revoked by the Hyderabad District Municipality Act 1956. The demonstration of 1956, anyway given that the board of trustees comprised under the demonstration of 1951 would proceed till the principal meeting of the panel chose under the demonstration of 1956 was called. Since no races were held the old board proceed in office for over three years, the most extreme time frame accommodated an advisory group to hold office under the Act of 1951. The appealing party petitioned God for a writ of quo warranto. The SC held if more than one development were conceivable the one which was smaller and neglected to accomplish the object of the Act ought to come up short. The Act ought to be so deciphered as to evade idiocy. In the current case since the Act of 1956 proceed with the advisory group established under the Act of 1951 till political decision occurred and the main gathering of new chosen individuals held, it is sensible to hold the arrangement of greatest time of residency of the council under old Act ought to likewise remain under new Act.

3. The Mischief Rule

The underhandedness rule is a standard of legal understanding that endeavors to decide the administrator's aim. Beginning from a sixteenth century case (Heydon's case) in the United Realm, its fundamental point is to decide the "underhandedness and deformity" that the rule being referred to has embarked to cure, and what administering would successfully actualize this cure. When the material words are equipped for bearing at least two developments the most solidly settled principle or development of such words "of all resolutions when all is said in done be they corrective or valuable, prohibitive or augmenting of the normal law is the standard of Heydon's case. The principles set down in this case are otherwise called Purposive Construction or Mischief Rule. The last principle of legal understanding is the naughtiness rule, under which an appointed authority endeavors to decide the administrator's expectation; what is the "underhandedness and deformity" that the resolution being referred to has embarked to cure, and what administering would successfully actualize this cure? The great explanation of the naughtiness decide is that given by the Barons of the Court of Exchequer in Heydon's Case (1854): for the sure and valid translation of all resolutions when all is said in done, four things are to be perceived and thought of: 1. What was the custom-based law before the creation of the Act?

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2. What was the underhandedness and imperfection for which the precedent-based law didn't give? 3. What cure the Parliament hath settled and named to fix the illness of the Commonwealth? 4. The genuine explanation of the cure; and afterward the workplace of all the appointed authority is consistently to make such development or will smother unobtrusive innovations and avoidances for duration of the underhandedness and expert private commodo, and to include power and life to the fix and cure, as indicated by the genuine goal of the creators of the Act. The wickedness rule is a sure guideline that judges can apply in legal understanding so as to find Parliament's expectation. It basically poses the inquiry: By making an Act of Parliament what was the "wickedness" that the past law didn't cover?

UTILIZATION OF THIS RULE

This standard of development is of smaller application than the brilliant principle or the plain importance rule, in that it must be used to decipher a resolution and, carefully, just when the rule was passed to cure an imperfection in the normal law. Administrative purpose is controlled by looking at optional sources, for example, council reports, compositions, law survey articles and comparing resolutions. This standard has frequently been utilized to determine ambiguities in cases in which the exacting principle can't be applied. On account of Thomson versus Master Clan Morris, Lord Lindley M.R. expressed that in deciphering any legal sanctioning respect must be had not exclusively to the words utilized, yet additionally to the historical backdrop of the Act and the reasons which lead to its being passed. On account of CIT versus Sundaradevi (1957) (32 ITR 615) (SC), it was held by the Apex Court that except if there is an equivocalness, it would not be available to the Court to leave from the typical standard of development which is that the expectation of the assembly ought to be fundamentally to accumulate from the words which are utilized. It is just when the words utilized are questionable that they would remain to be analyzed and considered on encompassing conditions and intrinsically proposed rehearses. The Supreme Court in Bengal Immunity Co. V. Condition of Bihar, (AIR 1995 SC 661) applied the naughtiness rule in development of Article 286 of the Constitution of India. In the wake of alluding to the condition of law winning

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in the region before the constitution as likewise to the disorder and disarray that was realized in between state exchange and business by unpredictable exercise of burdening powers by the unique Common Legislatures established on the hypothesis of regional nexus, Chief Justice S.R.Das, expressed "It was to fix this naughtiness of different tax assessment and to safeguard the free stream of interstate exchange or trade in the Union of India viewed as one monetary unit with no common hindrance that the constitution producer embraced Article 286 in the constitution".

Mischief Rule is pertinent where language is prepared to do more than one significance. It is the obligation of the Court to make such development of a sculpture which will stifle the naughtiness and advance the cure.

ADVANTAGES OF MISCHIEF RULE

1. The Law Commission considers it to be an unmistakably more acceptable method of deciphering goes about rather than the Golden or Strict guidelines.

2. It as a rule maintains a strategic distance from out of line or silly outcomes in condemning.

3. Closes provisos

4. Permits the law to create and adjust to changing needs model Royal College of Nursing v DHSS Impediments

DISADVANTAGES OF MISCHIEF RULE

1. It supposedly is obsolete as it has been being used since the sixteenth century, when customary law was the essential wellspring of law and parliamentary matchless quality was definitely not built up.

2. It gives a lot of capacity to the selected legal executive which is contended to be undemocratic.

3. Makes a wrongdoing after the occasion model Smith v Hughes, Elliot v Gray in this way encroaching the standard of law.

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4. Gives passes judgment on a law making job encroaching the partition of forces and Judges can bring their own sees, feeling of profound quality and preferences to a case model Smith v Hughes, DPP v Bull.

5. It is viewed as obsolete as it has been being used since the sixteenth century, when precedent- based law was the essential wellspring of law and parliamentary incomparability was not set up.

6. It gives an excessive amount of capacity to the appointed legal executive which is contended to be undemocratic.

7. In the sixteenth century, the legal executive would regularly draft acts for the benefit of the lord and were in this manner all around qualified in what underhandedness the demonstration was intended to cure.

8. It can make the law unsure.

4. BASIC/CRITICAL ANALYSIS OF BRILLIANT GUIDELINE AND WICKEDNESS RULE

The understanding of rules is fundamental to the organization of equity. They are the apparatuses that judges use to peruse significance to arrangements of the law so as to legitimize Their choices. Translation of resolutions is a significant issue which isn't made simple because of changing elements. One of them is that words don't for the most part have static implications. The use of certain words change with time. Beck versus Smith 1996 This at that point makes the understanding of resolutions not as basic as one would might suspect. Likewise, there could be cases where the immediate understanding of words could prompt ludicrousness. Or then again there could likewise be circumstances where the expectation of the governing body isn't very much communicated in the translation of rules.

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THE GOLDEN RULE The brilliant guideline was planned on account of where it was given that the strict translation of a resolution ought to be utilized distinctly to the degree that it would not create idiocy or then again discredit from the aim of the governing body. In the event that the exacting understanding of the rule were to deliver idiocy, at that point the aim of the lawmaking body ought to be applied. The brilliant guideline was applied on account of Council of College of Ibadan versus Adamolekun where the court needed to decipher the arrangement of S.3 (4) of the constitution (suspension and alteration order) of 1966 which states that where a declaration is in strife with a pronouncement, the proclamation is to become void to the degree of its irregularity with the order. In any case, in S.6 it was given that no inquiry as to the legitimacy of an announcement or proclamation was to be engaged in a court. The court decided that it would prompt craziness to actually decipher the arrangement of S.6 because of the way that on the off chance that it did, how at that point would it have the option to authorize the arrangements of S.3 (4). Hence, the declaration was held to be voided by the arrangements of S.3 (4). Issues with the brilliant guideline I. Judges can include or change the importance of rules what's more, subsequently become legislators encroaching the division of forces. II. Judges have no capacity to mediate for unadulterated shamefulness where there is no ridiculousness advantages of the brilliant rule . III. Errors in drafting can be remedied quickly.

REQUIREMENT FOR INTERPRETATION

In his The Law-Making Process, Michael Zander gives three reasons why legal translation is fundamental: 1. Unpredictability of rules with respect to the idea of the subject, various sketchers and the mix of lawful and specialized language can bring about ambiguity, obscure and vague language. 2. Expectation of future occasions prompts the utilization of vague terms. The unthinkable assignment of foreseeing each conceivable situation likewise prompts the utilization of vague language. Judges along these lines need to decipher rules in light of the holes in law. Models of

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uncertain language incorporate words, for example, "sensible". For this situation the courts are answerable for figuring out what establishes "sensible". 3. The multifaceted idea of language. Language, words also, phrases are an uncertain type of correspondence. Words can have numerous definitions and implications. Each gathering in court will use the definition and which means of the language generally invaluable to their specific need. It is dependent upon the courts to choose the most right utilization of the language utilized. 4. General Rules of Interpretation, Internal Aids to Translation, External Aids to Interpretation, Literal Rule, Golden Rule, Mischief Rule, Subsidiary Rules what's more, Harmonious Construction are probably the most significant standards.

5. CONCLUSION Translation of resolutions is prime capacity of court. Assembly orders the law and it gives in the possession of court to decipher it at whatever point there is contest. Since the desire of governing body is communicated in type of rule. Resolution is the beginning stage of translation. Court needs to offer importance to the resolution according to the goal of legislator which was at the hour of making law. Courts shouldn't decipher law subjective. They need to adhere to specific principles, for example, strict significance, brilliant principle and wickedness rule. It additionally needs to keep agreeable principles and read rule all in all while doing deciphering law. Naughtiness rule is most seasoned standard of translation which developed in 1584 for Heydon's situation. Object of naughtiness rule is to smother the deformity of law and advance the cure gave for. If there should arise an occurrence of equivocalness and imperfection in law, court need to consider four things that is what was the law before existing law, what is imperfection which isn't assume to be in the law, for what reason cure is given in the law and what is valid reason of cure. The aim of the Legislature is essentially to be accumulated from the language utilized in the resolution, hence focusing to what exactly has been said as additionally to what in particular has not been said. At the point when the words utilized are not equivocal, exacting significance must be applied, which is the brilliant standard of understanding. 'The brilliant principle is that the expressions of a rule must prima facie be given their normal importance'. Common and customary which means of words. The 'Brilliant principle' is actually an adjustment of the exacting standard. It is a helpful guideline, in the development of a rule, to hold fast to the conventional significance

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of the words utilized, and to the linguistic development, except if that is at change with the expectation of the governing body, to be gathered from the rule itself, in which case the language might be changed or changed, in order to keep away from such bother, yet no further. The brilliant principle is regularly applied to determine equivocalness in legal language for that importance which will best accomplish the goal of the governing body uncovered by the rule overall. As it tends to be seen from the case, naughtiness rule can be applied contrastingly by various appointed authorities. It is predominantly about the caution and comprehension of the individual applying it. However, it as an unmistakably more agreeable method of deciphering acts instead of the Golden or Literal guidelines. It typically keeps away from vile or ludicrous outcomes in condemning yet it additionally observed to be obsolete as it has been being used since the sixteenth century, when customary law was the essential wellspring of law and parliamentary matchless quality was not built up. It gives as well much capacity to the appointed legal executive which is contended to be undemocratic. In the sixteenth century, the legal executive would frequently draft follows up in the interest of the lord and were thusly well qualified in what underhandedness the demonstration was intended to cure. This isn't frequently the situation in present day legitimate frameworks. The standard can make the law questionable, defenseless to the dangerous slant. In this manner Purposive understanding was presented as a type of substitution for the naughtiness rule, the plain which means rule and the brilliant guideline to decide cases. The purposive methodology is a way to deal with legal and established translation under which precedent- based law courts decipher an authorization (that is, a rule, a piece of a rule, or a condition of a constitution) considering the reason for which it was sanctioned.

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REFERENCES 1. JGP Singh. “ Principles of Statutory Interpretation”, Wadhawa & Co. Nagpur, 9th Edition, 2004 2. Anurag Deep, “Interpretation of Statutes” XL VIII ASIL 551-601 (2012). 3. Richard A Posner, Reflections on Judging, 232 (Harvard University Press, 2013). 4. https://www.taxmanagementindia.com/visitor/detail_art icle.asp?ArticleID=6344 5. https://definitions.uslegal.com/m/mischief-rule/ 6. https://www.lawctopus.com/academike/mischief-rulestatutory-interpretation 7. www.legaldesire.com/literal-rule-and-mischief-ruleinterpretation 8. https://www.lawctopus.com/academike/golden-ruleinterpretation 9. https://www.iilsindia.com/blogs/2015/05/20/goldenrule-of-interpretation 10. Citation of Cases 11. AIR 29 1962 SCR (3) 592 12. AIR 1980 Kant 142 11. AIR 29 1962 SCR (3) 592 12. AIR 1980 Kant 142 13. AIR 16 1950 SCR 852 14. Smith v Hughes [1960] 1 WLR 830 15. Royal College of Nursing v DHSS [1981] 2 WLR 279 16. Elliot v Grey [1960] 1 QB 367 17. Corkery v Carpenter [1951] 1 KB 102 18. DPP v Bull [1995] QB 88 19. Brown v Brown [1980] 1 NZLR 484 20. AIR 832, 1958 SCR 1 21. AIR 628, 1957 SCR 930 22. Adler v George (1964) 23. CIT v. Sundaradevi (1957) (32 ITR 615) (SC) 24. AIR 1955 SC 661 25. Sutters v. Briggs [1922 (1) Appeal Cases 1] 26. Appeal (civil) 14743 of 1996 27. Maumsell v. Olins, (1975) AC 373 28. Navinc 28. Navinchandra Mafatlal v. CIT, Bombay (1955) 1 SCR 829, 836-7

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