HEYDON'S CASE 76 ER 637

SUBMITTED BY: - Ashish Raj Sarraf

BATCH: - BALLB (Energy Law)
SAP ID- 500093383
ROLL NO.- R450221061

CASE NAME Heydon’s case

CITATION EWHC Exch J36 3 Co Rep 7a 76 ER 637 Pasch 26 Eliz plea

began 20 Eliz Rot 140

COURT Exchequer of Pleas

BENCH Roger Manwood CB

APPELLANT Heydon

RESPONDENT Representatives of the church

DECIDED ON 1584

INTRODUCTION
The Case of Heydon (1584) The mischief rule of statutory construction was first used in the
famous case EWHC Exch J36. This rule is more flexible than the golden rule or the literal
rule. It tells judges to do four things to make sure the law fills in any holes.

Laws, leases, and life estates were all part of the case. Ware the father and Ware the son were
given a lease on a farm by Ottery College. This lease, which was based on copyhold, was
subject to the will of the master and the manor's customs. Heydon then rented the same piece
of land for eighty years. The Suppression of Religious Houses Act 1535 was passed by
Parliament and got rid of religious houses. The Act did, however, protect gifts that were made
more than a year before it was made law. The gift to the Wares was protected by the Court of
Exchequer, but Heydon's lease was thrown out.

FACTS
It was during Henry VIII's rule that laws were made to make property law better, especially
when it came to church lands. It used to be normal for ministers to lease or sell church land to
private people for long periods of time before these laws were made. A lot of the time, these
deals were bad because they let the clergy make money off of church land without giving the
church the money it was owed.
So that this issue would not happen again, Parliament made laws that make it harder for
ministers to give these types of leases or purchases. These rules were made to make sure that
the church could properly manage its land and that pastors couldn't use church land for their
own gain.
The fight in Heydon's Case began when a private person tried to claim land that they had
been given under one of these shady leases. The court had to decide how to read the law that
was meant to stop these gifts.
The main question was whether the private person's claim was valid given that the law only
let clergy give leases to certain people. The court had to figure out how to read the law
properly and decide if the person's claim was within the limits of what the law was meant to
stop.

KEY LEGAL ISSUE

Imagine you're a judge faced with a tricky legal puzzle. You have a law in front of you, but
the words aren't entirely clear. You need to figure out what the law means so you can apply it
to a specific case. This is essentially the situation judges faced in Heydon's Case.

The central question in Heydon's Case was how to interpret a law when its language is
confusing or unclear. The judges wanted to make sure they were interpreting the law in a way
that would fix the problem the law was meant to solve. They were looking for a way to
understand the "mischief" the law was trying to address and then interpret the law in a way
that would remedy that mischief.

It's like trying to solve a riddle or puzzle. You have the pieces, but they don't quite fit
together. You need to figure out the big picture and how each piece fits into it. In the case of
Heydon's Case, the judges needed to figure out the big picture of the law and how each word
and phrase fit into that picture.

JUDGEMENT
The Exchequer Court laid down a fundamental principle of statutory interpretation in this
case, now famously known as the Mischief Rule. The court held that when interpreting a
statute, judges must consider four key questions:
 1. What was the common law before the statute was enacted?
This asks what the legal situation was prior to the passage of the statute to understand
what the legislature intended to change or address.
2. What was the "mischief" or defect that the common law did not address?
This refers to the issue or problem that the common law could not solve, and which
led to the enactment of the statute.
3. What remedy did Parliament intend to provide by passing the statute?
This involves understanding what the legislature intended to achieve through the
statute in terms of correcting or solving the identified "mischief."
4. What was the true reason for the remedy?
This question focuses on the underlying purpose or policy objective that Parliament
sought to fulfill by enacting the law.
The court held that judges should interpret the statute in a way that effectively suppresses the
mischief and advances the remedy intended by Parliament. In other words, the interpretation
should give effect to the law’s purpose and not merely adhere to a literal reading of the
statute's words.

ARGUMENTS BY PETITIONER
The applicants said that before figuring out what a law means, it's important to find the
"mischief" or flaw that the common law didn't fix before the law was made. They made it
clear that this is where the court should begin when figuring out what the law means.
People said the court should pay attention to the specific goal the law was meant to achieve.
Once the court knew what the goal was, it could figure out how to use the law correctly to fix
the problem.
One important point the petitioners made was that the meaning of the law should be used to
lead interpretation. The applicants stressed that laws should be understood in light of what
Parliament meant to do to fix the problem and make things better.
Some people argued against taking laws at face value, saying that doing so could lead to silly
outcomes or miss the problem that the law was meant to fix. They pushed for a "purposeful
approach," which means that the law's meaning should be understood in a way that makes it
work the way it was meant to.
SIGNIFICANCE AND IMPACT
Heydon's Case established a key rule of statutory interpretation that continues to influence
courts in many jurisdictions around the world. The Mischief Rule allows judges to go
beyond the literal meaning of the words in a statute to ensure that the law's intended purpose
is fulfilled. It is particularly useful when the literal reading of the statute could lead to absurd
or unjust results or when the statutory language is ambiguous.
The Mischief Rule is often contrasted with other rules of statutory interpretation, such as:
Literal Rule: Which emphasizes a strict adherence to the plain, literal meaning of the words
of the statute.
Golden Rule: Which allows courts to depart from the literal rule in cases where a literal
interpretation would lead to absurd or unjust outcomes.
Unlike the Literal Rule, which focuses solely on the text, the Mischief Rule takes a more
purposive approach, encouraging judges to consider the broader objectives of the law.

RELEVANCE IN MODERN LAW

The principle from Heydon's Case remains relevant in contemporary statutory interpretation.
Although statutory interpretation today may involve more sophisticated tools like legislative
history and more detailed statutory language, the Mischief Rule continues to serve as an
important reminder that statutes are enacted to serve a purpose. Judges are encouraged to
interpret laws in ways that prevent the "mischief" the statute seeks to remedy and promote the
underlying legislative intent.
Many jurisdictions, including India and the UK, have incorporated the Mischief Rule into
their interpretative approaches. For instance, Indian courts frequently apply a purposive
interpretation to ensure that the spirit of the law is upheld, particularly in cases involving
social welfare or remedial legislation.

ARGUMENTS BY RESPONDENT
In their response, the respondents stressed the idea of judicial reserve, saying that the courts
shouldn't read the law in a way that goes beyond what Parliament wrote. They would say that
it wasn't the court's job to guess what the law was trying to do or what problem it was trying
to solve; it was only their job to follow the law as it was written.
Respondents said there wasn't a clear hole in the common law that needed to be filled by the
courts or interpreted in a wider way. For them, the common law might have been enough, and
the law should be read closely to avoid any effects that were not meant.
The applicants wanted a "purposeful" reading of the law, but the respondents said that the law
needs to be read strictly to protect the lawmakers' intentions. They might say that going
beyond the strict meaning would mean making new laws, which is not the courts' job but
Parliament's.
RATIO
The ratio decidendi of Heydon's Case (1584) 76 ER 637 set up the Mischief Rule of statutory
interpretation, which is a basic rule that helps judges figure out what the law meant. The court
said that judges must look at four main things when figuring out what a law means: (1) what
the common law was before the statute was made; (2) what the specific "mischief" or flaw in
the law was that the statute was meant to fix; (3) what the statute's remedy was for this
mischief; and (4) what the real reason for the remedy was. In this case, the "mischief" was
pastors abusing church property by renting it out without permission for personal gain. The
law was meant to stop this kind of exploitation, and the court said that any interpretation of
the law must try to achieve this goal by stopping the behavior that the law was meant to stop.
The Mischief Rule tells judges to ignore the exact words of a law and instead focus on what
it's meant to do.
CONCLUSION
Beyond the conflict over church lands, Heydon's Case (1584) 76 ER 637 was important
because it set the stage for a critical approach to statutory interpretation that still affects how
lawyers do their jobs today. The court's Mischief Rule gives judges a practical way to look at
not only the words of a law, but also what it's meant to do and the problems it aims to solve.
This method stresses how important context is in legal analysis, making sure that laws are
followed in a way that solves the problems they were made to fix.
The main point of Heydon's Case is to tell us that the law shouldn't exist in a vacuum; it
needs to be understood and applied in the context of society's needs and history. Courts can
make the law more fair and just by putting an emphasis on finding wrongdoing and
understanding what lawmakers were trying to do when they made laws. As laws change, the
rules set up in this case will still be useful. They tell judges how to balance interpreting texts
with the bigger goals of justice and fairness in court cases.