HeadingsChapter titlesSupreme Court of India

Bhinka v Charan Singh

AIR 1959 Supreme Court 96019591 min read
The case in brief30-second read
Facts
Provisions of a statute grouped under a chapter heading. Interpretation of a specific section was contested. One party relied on the chapter heading to restrict the section's scope.
Issue
What is the interpretive weight of headings and chapter titles in a statute?
Held
Headings are legitimate internal aids. They indicate the general drift of the provisions grouped under them.
Principle
Headings or chapter titles given to groups of sections indicate the general drift of the provisions grouped under them. They may be relied upon to determine the sense of the section where the language is ambiguous, but they cannot control the plain meaning of express words.
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Facts

  • Provisions of a statute grouped under a chapter heading
  • Interpretation of a specific section was contested
  • One party relied on the chapter heading to restrict the section's scope

Issue

  1. What is the interpretive weight of headings and chapter titles in a statute?

Held

  • Headings are legitimate internal aids
  • They indicate the general drift of the provisions grouped under them
  • Useful where the operative words are ambiguous
  • Cannot override or restrict clear enacting words

Ratio decidendi

Section headings and chapter titles are part of the context and may be used to resolve doubts about the meaning and scope of a provision. They cannot, however, control or restrict plain language in the operative section.

Exam use

How to use it in an answer

  • Paired with Burrakur Coal (1961) for same proposition
  • Stock citation for Part B on internal aids
  • Key line: "In Bhinka v. Charan Singh (1959), the Supreme Court held that headings given to groups of sections indicate the general drift of the provisions and are legitimate internal aids to interpretation."

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Citation

Bhinka v. Charan Singh AIR 1959 Supreme Court 960

Reported: AIR 1959 SC 960. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.