Bhinka v. Charan Singh
Rule established
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.
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
- 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.
How to use it in an exam
- 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."
Source
Source: AIR 1959 SC 960
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.