Plain meaning in Graduates' Constituencies: candidate qualifications cannot be expanded by implication beyond the constitutional text.

Article 171 creates Graduates' Constituencies only for the electorate and does not require the candidate returned from such a constituency to be a graduate. The constitutional and statutory scheme separately sets qualifications for electors and for members of the Legislative Council, and section 6 of the Representation of the People Act, 1951 requires only that a candidate be an elector for an Assembly constituency in the State. Because the text is clear, the plain meaning rule applies and no extra qualification can be read in from constitutional theory, legislative history, or presumed intent. The omission of a graduate qualification for candidates is treated as deliberate, so the additional requirement cannot be implied.

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Issues: Whether a person elected from a Graduates' Constituency to a Legislative Council must himself possess the qualification of being a graduate, and whether such a qualification can be implied by reference to constitutional scheme, legislative history, or presumed legislative intent.

Analysis: Article 171 of the Constitution provides for Graduates' Constituencies only as electorates of persons who have held degrees for the prescribed period; it does not state that the candidate returned from such a constituency must also be a graduate. The Constitution and the Representation of the People Act, 1951 separately prescribe qualifications for electors and for members of the Legislative Council, and Section 6 of the 1951 Act requires only that a candidate be an elector for any Assembly constituency in the State. The language is clear and unambiguous, so the ordinary rule of plain meaning applies and no further qualification can be interpolated on the basis of supposed functional or vocational representation. Legislative history also indicated that whenever a candidate qualification was intended, it was expressly enacted, and the omission of a graduate qualification for candidates from Graduates' Constituencies was therefore deliberate rather than accidental.

Conclusion: The additional qualification of being a graduate could not be implied, and the appellant was qualified to contest and be elected from the Graduates' Constituency.

Ratio Decidendi: Where the constitutional and statutory text clearly prescribes the qualifications for electors and candidates separately, courts cannot add an unstated qualification by implication, presumed intent, or legislative theory when the omission appears deliberate.

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