A statute has been enacted to criminalize the operation of a motor vehicle on a public road while under the influence of intoxicating substances. A defendant was charged with violating this statute after being arrested for driving his golf cart on a road while intoxicated. As per the Road Traffic Act 1988, a motor vehicle is defined as any mechanically propelled vehicle intended or adapted for use on the roads.
Which of the following methods of statutory interpretation would most likely lead to the defendant's conviction for the offence?
A statute has been enacted to criminalize the operation of a motor vehicle on a public road while under the influence of intoxicating substances. A defendant was charged with violating this statute after being arrested for driving his golf cart on a road while intoxicated. As per the Road Traffic Act 1988, a motor vehicle is defined as any mechanically propelled vehicle intended or adapted for use on the roads.
Which of the following methods of statutory interpretation would most likely lead to the defendant's conviction for the offence?
The mischief rule.
(C) According to the mischief rule, when interpreting a criminal statute, the judge must consider the problem that the statute aims to solve. In this case, the goal is to prevent harm caused by driving a vehicle on the road while intoxicated. As operating a golf cart on the road can be dangerous, the defendant can be convicted under the mischief rule.
(A) This option is incorrect because under the literal rule when a statute's words are unclear, courts use their ordinary meaning to interpret them. The term "motor vehicle" would likely refer only to cars, trucks, and motorcycles, not golf carts.
(B) This option is also incorrect. Under the golden rule, courts can use something other than a word's ordinary meaning to avoid absurd results. However, using the ordinary meaning of "motor vehicle" would not lead to an absurd outcome, so the golden rule cannot be used.
(D) The in pari materia rule means that a court will look at other statutes to help interpret ambiguous language. As the only other statute mentioned, the Road Traffic Act 1988, defines "motor vehicle" as a mechanically propelled vehicle intended or adapted for use on the roads, it would not lead to a conviction of a golf cart as it is not intended or adapted for use on the road.
(E) Expressio unius is a rule meaning that the expression of one thing excludes the inclusion of others. However, there are no other relevant definitions of "motor vehicle" in this case, so expressio unius is not relevant.