HeadingsInternal aidsSupreme Court of India

Burrakur Coal Co. v Union of India

AIR 1961 Supreme Court 95419611 min read
The case in brief30-second read
Facts
Coal company disputed liability under a specific section. The heading of the chapter/part grouping the section pointed in one direction. The operative words of the section were argued to have a different scope.
Issue
Whether headings or chapter titles in a statute can be used as aids to interpretation.
Held
Headings are part of the statute (unlike marginal notes in some jurisdictions)
Principle
Headings or titles prefixed to sections or groups of sections in a statute can be used as aids to construction. They indicate the general drift of the provisions grouped under them, though they cannot control the plain words of a section.
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Facts

  • Coal company disputed liability under a specific section
  • The heading of the chapter/part grouping the section pointed in one direction
  • The operative words of the section were argued to have a different scope

Issue

  1. Whether headings or chapter titles in a statute can be used as aids to interpretation.

Held

  • Headings are part of the statute (unlike marginal notes in some jurisdictions)
  • They indicate the general drift and purpose of the sections grouped under them
  • Where the operative words are clear, headings cannot restrict or expand them
  • But where ambiguity exists, headings provide valuable guidance

Ratio decidendi

Headings or titles prefixed to a section or a group of sections in a statute are regarded as preambles to those sections. They are relevant as an aid to construe the scope and purpose of the provisions grouped under them, but cannot control the plain meaning of the enacting words.

Exam use

How to use it in an answer

  • Indian authority on headings as internal aids
  • Paired with Bhinka v Charan Singh (1959) on same point
  • Key line: "In Burrakur Coal Co. v. Union of India (1961), the Supreme Court held that headings of sections indicate the general drift of provisions grouped under them and are legitimate internal aids to interpretation."

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Citation

Burrakur Coal Co. v. Union of India AIR 1961 Supreme Court 954

Reported: AIR 1961 SC 954. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.