LEGAL PRINCIPLE: STATUTORY INTERPRETATION – Construction of Statutes – Clear and Unambiguous Provisions – No Need for Harmonious Reading
PRINCIPLE STATEMENT
Where the words of a document or an enactment are clear and not ambiguous, they should be given effect to. Where there is no conflict in one part of an enactment and another and the provisions of the part which is relied on are plain and unambiguous, those provisions should be applied without the need to call in aid, other parts of the enactment. In the present case, there is no conflict between sections 9 and 14(1) and the provisions of those sections are plain and not at all ambiguous.
RATIO DECIDENDI (SOURCE)
Per Ayoola, JSC, in Akuneziri v. Okenwa & Ors (2000) NLC-1261997(SC) at p. 22; Paras B–C.
"Where the words of a document or an enactment are clear and not ambiguous, they should be given effect to. Where there is no conflict in one part of an enactment and another and the provisions of the part which is relied on are plain and unambiguous, those provisions should be applied without the need to call in aid, other parts of the enactment. In the present case, there is no conflict between sections 9 and 14(1) and the provisions of those sections are plain and not at all ambiguous."
EXPLANATION / SCOPE
The cardinal rule of statutory interpretation is that clear and unambiguous language must be given its plain meaning. Where a provision is unambiguous and there is no conflict with other sections, there is no need to resort to external aids or to read it together with other provisions. Harmonious construction is only required where ambiguity exists or where provisions appear contradictory. This principle prevents courts from importing extraneous limitations or engaging in unnecessary interpretive exercises when the legislative intent is already manifest from the plain text. Judicial restraint demands adherence to the clear words chosen by the legislature.