The contractor, however, must be aware that invoking its protections is a risky, and at best, requires a case-by-case analysis affording little predictive value as to outcome. 3.0 Cardinal Rules for Interpretation of taxing Statutes: 3.1 Rule of literal interpretation – This is the most widely used Rule of Interpretation in taxing statutes. (a) CIT v. T.V. According to this rule, words must be given their ordinary, literal, grammatical meaning. In sum, the Cardinal Change Rule provides contractors limited protection against excessive changes. This is an appeal against the decision of the High Court of Justice of Rivers State, Port Harcourt Judicial Division delivered on September 10, 2015.By an originating summons, the Claimants/1st Respondent submitted the following question for determination Fast and free shipping free returns cash on delivery available on eligible purchase. In an English case Hess v The State (1895) 2 O.R.C. This rule applies to the interpretation of constitutional and statutory provisions alike. Buy Cardinal Rules of Legal Interpretation by Anonymous online on at best prices. This rule comes directly from the English law. 9. Welfare, social and beneficial statutes are not to be construed strictly. Doubts are resolved in favour of the class of persons for whose benefit the statute is enacted. To help the court find β€œan interpretation that reflects and promotes the intention of the parties at the time they entered into the contract.” [Consolidated Bathurst Export Ltd. v. Mutual Boiler and Machinery Insurance Co., [1980] 1 S.C.R. The literal rule is the first rule to be used in establishing the intention of the legislature. Cardinal rules of legal interpretation London : Stevens and Sons ; Toronto : Canada Law Book Co., 1908.; 817 pages, 804 with full-text search Help View This is the cardinal rule of construction (interpretation) of statutes. : Multiple Contributors, See Notes Multiple Contributors: 9781241131647: Books - Some decisions are given hereunder. On the other hand penal and taxing statutes and statutes excluding Court's jurisdiction should be strictly construed. Cardinal Rules of Legal Interpretation. This rule is also one of the cardinal rules of interpretation when the words of a taxing statute are ambiguous and incapable of a literal interpretation and generally takes into account four parameters, namely i) What was the Law prior to enactment of the statute in question;