Sussex Peerage Case
The literal rule: where the words of a statute are clear, they must be given their natural and ordinary meaning.
Facts
Augustus d'Este, the son of the Duke of Sussex, claimed to succeed to his father's peerage. His claim depended on whether his parents' marriage, which had taken place in Rome without the consent of King George III, was valid. The Royal Marriages Act 1772 provided that any marriage of a descendant of George II made without the consent of the monarch would be void. The question was whether the Act applied to marriages celebrated outside England.
Legal principle
The House of Lords held that the Act applied to marriages wherever they were celebrated, so the marriage was void and the claim failed. Tindal CJ said that the only rule for the construction of Acts of Parliament is that they should be construed according to the intent of the Parliament which passed the Act, and that if the words of the statute are in themselves precise and unambiguous, then no more can be necessary than to expound those words in their natural and ordinary sense, because the words themselves alone do best declare the intention of the lawgiver. This is a classic statement of the literal rule.
Related cases on statutory interpretation
- Adler v George [1964] 2 QB 7
- Black-Clawson International Ltd v Papierwerke Waldhof-Aschaffenburg AG [1975] AC 591
- Corkery v Carpenter [1951] 1 KB 102
- Grey v Pearson (1857) 6 HLC 61
- Heydon's Case (1584) 3 Co Rep 7a
- Inco Europe Ltd v First Choice Distribution [2000] 1 WLR 586
- Jones v Tower Boot Co Ltd [1997] ICR 254
- London and North Eastern Railway Co v Berriman [1946] AC 278
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