Same Nature / The Revival of Ray LXXX

The expression ‘of the same nature’ in Section 83 of The Motor Vehicles Act, 1988 can have multiple meanings. This phrase, in its natural expression, would only mean having similar features. But then, would ‘same’ mean similar, identical, equivalent, comparable, interchangeable or related? Likewise, would ‘nature’ mean type, feature, texture, make, model, design, or generation?

These are open textual expressions, used in normal course to convey a meaning which Legislature would not have intended to be read in a pedantic manner. When words allow multiple interpretations, Courts of Law have developed art and technique of finding the correct meaning by looking at words in their context. This approach is beautifully expressed by Justice O. Chinnappa Reddy in Reserve Bank of India v. Peerless General Finance Investment Co. Ltd., (1987) 1 SCC 424. We would notice a similar approach adopted by this Court in Vijayawada Municipal Corporation, (1976) 4 SCC 548 and Subha Rao Hanumatharao Prayag, (1976) 4 SCC 830.

Assuming ‘same nature’ is confined only to mean: “a bus by bus, a mini-bus by mini-bus and not bus by a minibus…”, is not a correct way to read. In fact, expressions such as this are better kept open ended to enable Courts to subserve needs of changing circumstances.

Hon’ble Justice Pamidighantam Sri Narasimha, Regional Transport Authority v. Shaju, [Civil Appeal No. 1453-1454 of 2022].