Inland Revenue Commissioners v. Frere
Rule established
Where a word appears in different sections of the same statute, there is a presumption of uniform meaning (same word, same meaning throughout). However, this presumption yields where the context clearly requires a different meaning in different sections.
Facts
- "Interest" appeared in several sections of the Income Tax Act
- In some sections it clearly had a broad meaning; in others, a narrow one was argued
- Revenue contended one uniform meaning should be applied throughout
Issue
- Whether the same word must bear the same meaning in every section of the same statute.
Held
- Presumption of uniform meaning exists (consistency in statutory language)
- But the presumption is rebuttable by context
- Where the legislative purpose of different sections requires it, the same word may bear different meanings
- Context prevails over mechanical uniformity
Ratio Decidendi
There is a presumption that the Legislature uses the same word with the same meaning throughout a statute. But this is only a presumption. It yields where the context of a particular provision, or the purpose of the section, plainly requires a different shade of meaning.
How to use it in an exam
- Authority for the "same word, same meaning" presumption and its limits
- Internal aid: consistency principle
- Key line: "In IRC v. Frere (1965), the House of Lords held that there is a presumption of uniform meaning for the same word throughout a statute, but context may rebut this presumption."
Source
Source: [1965] AC 402
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.