“Diwan Bros. v. Central Bank of India, (1976) 3 SCC 800 referred to the well-known dictum of Lord Buckmaster in Barras v. Aberdeen Steam Trawling and Fishing Company, 1933 AC 402.

“It has long been a well-established principle to be applied in the consideration of Acts of Parliament that where a word of doubtful meaning has received a clear judicial interpretation, the subsequent statute which incorporates the same word or the same phrase in a similar context must be construed so that the word or phrase is interpreted according to the meaning that has previously been ascribed to it.”

Also see, Shree Bhagwati Steel Rolling Mills v. CCE (2016) 3 SCC 643.”

– Hon’ble Justice R.F. Nariman, M/s. Bangalore Club v. Commissioner of Wealth Tax, [Civil Appeal Nos. 3964-71 of 2007].

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Lord Denning famously caricatured Lord Buckmaster as a ‘timorous soul’ in contrast to Lord Atkin’s ‘bold spirit’ [Candler v. Crane, Christmas & Co., [1951] 2 KB 164, 178].

“I have been reading with admiration your magnificent and convincing Judgment in The Snail Case – also Macmillan’s which is very good. I am glad, this fundamental rule of law will now be finally established. I find Buckmaster on Snails very disappointing.”

– Letter from Lord Wright to Lord Atkin, May 12, 1932.