Strict construction requires that the court must not read anything into the statute by implication or extend its meaning by analogy.
1. Strict Construction of Taxation Laws
Taxation acts as an expropriation of private property. Therefore, taxing statutes must be construed strictly.
- Principle: There is no room for equity or intendment in a tax statute. One has to look strictly at the words used. If the subject falls within the letter of the law, they must be taxed; if not, they cannot be taxed by implication.
- Ambiguity: If a tax provision is capable of two reasonable interpretations, the benefit must go strictly to the assessee (taxpayer), not the state.
- Landmark Case: Commissioner of Wealth Tax v. Krupa (1965): The Supreme Court held that in a taxing statute, courts cannot stretch the language to cover a case that falls outside the plain words, nor can they import equitable considerations to prevent tax avoidance.
2. Strict Construction of Penal Laws
Statutes that create offenses and impose penalties (imprisonment or fines) must be construed strictly to protect individual liberty.
- Rule: The offense must be clearly defined. If a penal provision has two interpretations, the court must adopt the construction that favors the accused. No person can be brought within a penal charge by extending the words of the statute through analogy or implication.