Literal interpretation means that the words of a statute must be given their plain, ordinary, and natural meaning, without adding or omitting anything. This principle is based on the Latin maxim: “Verbis legis non est recedendum” which means that,“There is no departure from the words of law.” If the meaning is clear, the court must enforce the law as written. The court should not make any assumptions or creativity while interpreting law as per principle of literal interpretation. It is also known as Grammatical Interpretation because it relies on grammatical rules.
Objective of This Rule
To understand the intention of the legislature purely from the words used in the statute. The assumption is that the legislature speaks clearly and means what it writes.
Key Rules of Literal Interpretation
- Words must be interpreted accurately, using their natural and grammatical meaning.
- Primary (ordinary) meaning is used while interpreting, and secondary meaning should be used only if it is clearly intended by the legislature.
- Use the prevailing, current meanings of words at the time of enactment.
- Legal, technical, or professional terms should be interpreted in their proper legal context. Example: “Sale” and “Agreement to Sale” are legally different and must be treated accordingly.
Landmark Cases on Literal Interpretation
1. Ramavatar vs Assistant Sales Tax Officer (AIR 1961 SC 1325)
Issue: In this case the question before the court was that whether the sale of betel leaves was subject to sales tax or not as per the Central Provinces and Berar Sales Tax Act, 1947 ? In this case appellant contended that betel leaves are vegetable as per the dictionary meaning of the word vegetable.
Held: Supreme Court in this case held that the word betel leaves could not be given the dictionary meaning when the ordinary and natural meaning of word betel leaves are clear and unambiguous. So Betel leaves are not vegetable and hence sales tax can be levied on it.
2. Ranjit Udeshi vs State of Maharashtra (AIR 1965 SC 881)
Issue: In this case the appellant was convicted under section 292 of the Indian Penal code for the sale of an obscene book which is banned by the Government of India. In this case the appellant contended that he does not have the knowledge of obscenity contained in the book. He further argued that the book sellers sell large no. of books and is not expected to know the contents of each book.
Held: Supreme court in this case held that the knowledge of obscenity is not an essential element of the offence under section 292 of the Indian Penal Code and the court must give the natural meaning of words used in the section.
3. Sonia Bhatia vs State of U.P. [1981 SCR (3) 239]
In this case it was held that when words have a well-known, popular meaning, they must be interpreted that way unless defined otherwise.
4. State of Kerala vs Mathai Verghese [(1986) 4 SCC 746]
In this case the supreme court applied the rule of literal interpretation while interpreting the expression Currency note and bank note under section 489A and 489 E of IPC. In this case the court held that since the word Indian is not written before currency and bank notes, hence the intention of lawmakers is to include both the foreign and Indian currency and bank notes.
5. Karnataka State Financial Corporation vs N. Narsimahaiah (AIR 2008 SC 1797)
In this case it was held that object of the Act is relevant only when the language is unclear. If words are clear, literal meaning is to be applied.
6. Nemai Chandra Kumar vs Mani Square Ltd. (AIR 2015 SC 2955)
In this case it was held that literal rule is the first rule to be applied. If the language of statute is plain, there’s no need to look beyond the statute.
Final Thought
Literal interpretation ensures that the judge remains an interpreter—not a lawmaker. If the words are clear, there is no scope for assumptions. 🧠⚖️
“When the language of a statute is plain, the duty of the court is simple—interpret and apply.” ✍️
References:
- Interpretation of Statute by Prof. T. Bhattacharya
- Interpretation of statutes by B.M. Gandhi
