Deliberate punctuation in statutory instruments may guide interpretation despite minor drafting aberrations.

The petitioners sought review of the Delhi High Court’s earlier judgment concerning the interpretation and supersession of the 2010 and 2012 Recruitment Rules governing Group ‘A’ Combatised (General Duty) posts in the Sashastra Seema Bal.

The review challenge principally concerned the significance attributed to the absence of a comma in the preamble to the 2012 Rules.

The Union of India and other respondents had challenged the original judgment before the Supreme Court in SLP (C) Nos. 14175–14176/2026.

The Supreme Court, after hearing the parties, dismissed the SLPs, finding no reason to interfere with the High Court’s judgment.

The petitioners thereafter filed the review petition with a delay of 276 days, contending that the Supreme Court’s dismissal in limine did not create a bar to review and that the punctuation in the 2012 Rules was so defective that it could not support the High Court’s interpretation.

Whether the dismissal of the SLPs by the Supreme Court, after hearing the parties and finding no reason to interfere, prevented or otherwise affected the maintainability of the review petition before the High Court.

Whether the alleged punctuation, drafting and typographical defects in the preamble to the 2012 Recruitment Rules rendered the absence of a comma after the words “insofar it relates to the post of Assistant Commandant” irrelevant for interpreting the scope of supersession.

Whether the petitioners had shown sufficient cause for condoning the 276-day delay in filing the review petition.

The Court applied the principle that review jurisdiction cannot be invoked on grounds lacking substance or as a means of reopening an issue already considered, particularly where the petition is lacking in bona fides.

It relied on the Supreme Court’s order dismissing the SLP after hearing the parties at length as demonstrating that the original judgment had been duly considered and that no interference was warranted.

On statutory interpretation, the Court relied on Colour-Chem Ltd. v. A.L. Alaspurkar, (1998) 3 SCC 192, for the proposition that punctuation may assist interpretation.

State of Gujarat v. Reliance Industries Ltd., (2017) 16 SCC 28, which approved the significance of punctuation in an appropriately drafted statutory provision while also referring to Jamshed N. Guzdar v. State of Maharashtra, (2005) 2 SCC 591, and Ashwini Kumar Ghosh v. Arabinda Bose, AIR 1952 SC 369.

The Court further relied on Indore Development Authority v. Manoharlal, (2020) 8 SCC 129, regarding the importance of punctuation in interpreting statutory instruments.

The Court rejected the contention that the SLP dismissal was an unreasoned order incapable of affecting the review proceedings.

It emphasised that the Supreme Court had heard the parties at length and had expressly found no reason to interfere with the High Court’s judgment.

On merits, the Court held that the petitioners’ reliance on minor drafting defects—such as inconsistent hyphenation, parentheses, capitalisation, commas between the name of the Rules and the year, and omission of the word “as”—could not negate the interpretive significance of the specific absence of a comma after “insofar it relates to the post of Assistant Commandant”.

The Court treated that punctuation as materially connected to the structure and meaning of the supersession clause, distinguishing it from routine typographical or formatting irregularities.

It therefore found no error warranting review and held that the petition had been filed belatedly, without a sustainable explanation, after the respondents began implementing the judgment following the Supreme Court’s order.

The 276-day delay was not supported by any sustainable cause, and the review petition was found to be lacking in bona fides.

The petition was accordingly dismissed with costs of ₹25,000, payable to the Delhi High Court Legal Services Committee within four weeks.