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The Rule of Harmonious Construction directs that a statute be read as a whole to avoid conflict between provisions. In which Supreme Court case did the Court resolve a conflict between Articles 25(2)(b) and 26(b) of the Constitution using this rule?
Answer & Solution
Correct answer: C.
1. The Supreme Court in **Venkataramana Devaru v. State of Mysore, A.I.R. 1958 S.C. 255** applied the Rule of Harmonious Construction to resolve the conflict between Articles 25(2)(b) and 26(b).
2. The Court held that the right of every religious denomination or any section thereof to manage its own affairs in matters of religion under Article 26(b) is **subject to** a law made by a State providing for social welfare and reform or throwing open Hindu religious institutions of a public character to all classes and sections of Hindus under Article 25(2)(b).
3. Both Articles were read together rather than allowing one to nullify the other — a textbook illustration of harmonious construction.
4. *Raj Krishna v. Pinod Kanungo* states the general rule of avoiding head-on clashes; *New India Sugar Mills* states that expressions should be so understood as to harmonise with the object of the statute; *Tirath Singh* concerns Reasonable Construction.
_Source: ICSI CS Executive — Lesson 3, 'Rule of Harmonious Construction', p. 88._
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