In the State of Rajasthan, a land reform statute was enacted to protect tenants from eviction and to ensure security of tenure. The law prohibited eviction of tenants except under specific conditions. However, the wordin

The case situation attracts the mischief rule or the Heydon's rule. In Heydon's Case , in [1584] [76 ER 637 360 REP 7a], it was resolved by the Barons of the Exchequer that, for the sure and true interpretation of all statutes in general (be they penal or beneficial, restrictive or enlarging of the Common Law) four things are to be discerned and considered: What was the Common Law before the making of the Act; What was the mischief and defect for which the Common Law did not provide; What remedy the Parliament had resolved and appointed to cure the disease of the Commonwealth; and The true reason of the remedy. Although judges are unlikely to propound formally in their judgments the four questions in Heydon's Case, consideration of the "mischief" or "object" of the enactment is common and will often provide the solution to a problem of interpretation. Therefore, when the material words in question are ambiguous and are capable of bearing two or more constructions, the most firmly established rule for construction of such words is the rule laid down in Heydon's case. The rule directs that the Courts must adopt that construction which "shall suppress the mischief and advance the remedy". ( Umed Singh v. Raj Singh, A.I.R. 1975 S.C. 43 ) Thus, under the Mischief Rule (Heydon's Case), courts must consider the defect (mischief) in the previous law and interpret the statute to suppress the mischief and advance the remedy. In Umed Singh v. Raj Singh , the Court emphasized purposive interpretation, especially in beneficial legislation like tenancy laws, to protect weaker sections. In the given situation, we can say that the law aims to protect tenants from eviction as it is a beneficial legislation. Evicting Mohan would defeat the purpose of the statute. Even if wording is ambiguous, interpretation should favour tenant protection. Mohan is entitled to protection, as the statute must be interpreted to advance its beneficial object.