When two interpretations of a statute are possible, the Court may prefer and adopt the purposive interpretation having regard to object and intent of such a statute. Article 141 states that the law declared by the Supreme Court shall be binding on all Courts. To give this article a purposive interpretation it was settled that the expression ‘all the courts’ means all the Courts except the Supreme Court.
The Supreme Court is said to be the Guardian and Custodian of the Constitution and is vested with the magnificent task of interpreting and implementing the provisions of the Constitution to the best of the public interest and welfare. Hence in interpreting Article 141 of the Constitution of India the Supreme Court in the case Bengal Immunity Co. V State of Bihar (AIR 1955 SC 661)laid down that there is nothing in the Constitution of India which stops or prevents the Supreme Court in digressing from its previous decision if it is convinced of its error and its toxic effect on the general interest of the public. In addition to it the Court held that it is compulsory for the judicial conscience to rectify its error.
It can be judged that the Supreme Court in giving such an interpretation to Article 141 has given the utmost significance to the interest of the society and people at large and has demonstrated a mark of heroism in showing the courage and valour to accept and rectify its mistakes rather than allowing it to perpetuate into the country’s polity and the legal set-up of the judiciary.
Justice Bronson in Pierce v. Delameter (AIR 2011 SC 1989) dealing with the similar view held that a judge ought to be wise enough to know that he is fallible and, there, ever ready to learn: great and honest enough to discard all mere pride of opinion and follow truth wherever it may lead: and courageous enough to acknowledge his errors.
Thus it can be well concluded that by not including the Supreme Court under the expression all courts under Article 141 of the Indian Constitution the Judiciary has given a purposive interpretation to this article thereby upholding the importance and significance of interpretation of statutes.
