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Uses the Mimansa principle to interpret the meaning of Animal Driven Vehicle Matter of regret that the principles are rarely used in courts now New Delhi: Mimansa Rules of Interpretation (MRI) were still relevant and could be effectively used in courts whenever there was difficulty or ambiguity in interpreting a principle or to understand the meaning of a word, the Supreme Court has held. “It may be mentioned that the MRI were our traditional principles of interpretation laid down by Jaimini whose Sutras were explained by Shabar, Kumarila Bhatta, Prabhakar, etc. These Mimansa Principles were regularly used by our great jurists such as Vijnaneshwar [author of Mitakshara], Jimutvahana [author of Dayabhaga], Nanda Pandit [author of Dattak Mimansa] etc. whenever they found any conflict between the various Smritis or any ambiguity or incongruity therein. There is no reason why we cannot use these principles on appropriate occasions,” said a Bench consisting of Justices A.K. Mathur and Markandey Katju. The Bench used the Mimansa principle to interpret the meaning of ‘Animal Driven Vehicle’ and whether this would come within the ambit of ‘agricultural implement.’ U.P. conditionThe Uttar Pradesh government imposed a condition that agricultural implements operated by hand or animal power should be purchased from the U.P. State Agro Industrial Limited for availing itself subsidy. The Allahabad High Court held that ADV would fall within the definition of agricultural implement. Allowing the appeal, a Bench of Justice Mathur and Justice Katju quoted the Mimansa principle and said whenever there was more than one meaning to a commonly used word the “popular meaning” would overpower the “etymological meaning.” It held that the ADV would not come within the meaning of agricultural implement. The Bench said: “It is a matter of deep regret that Mimansa principles have rarely been used in our law courts. It is nowhere mentioned in our Constitution or any other law that only Maxwell’s Principles of Interpretation can be used by the court. We can use any system of interpretation which helps us solve a difficulty. In certain situations Maxwell’s principles would be more appropriate, while in other situations the Mimansa principles may be more suitable. “Since we have used a Mimansa principle in this judgment we thought it necessary to briefly mention about the Mimansa principles [the original works are in Sanskrit, but there is an elucidating book in English by K.L. Sarkar called The Mimansa Rules of Interpretation published in the Tagore Law Lecture],” it added.
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