Beneficial statute interpretation treats "before" as including the stated date, validating a 1 April filing.

The Bombay HC construed the phrase "before the 1st day of April 1970" in section 3 of the Maharashtra (Vidarbha Region) Agricultural Debtor's Relief Act, 1969 as ambiguous in the context of a beneficial relief statute. Reading section 3 with sections 6 and 13, and taking account of the legislative history extending the filing period to 1 April 1970, the Court held that "before" could mean "upto" or "not later than" rather than excluding that date. An application filed on 1 April 1970 was therefore treated as within time. The Court found it unnecessary to decide whether section 5 of the Limitation Act, 1963 applied.

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Issues: Whether the expression "before the 1st day of April 1970" in section 3 of the Maharashtra (Vidarbha Region) Agricultural Debtor's Relief Act, 1969 included an application filed on 1 April 1970.

Analysis: The provision was part of a beneficial enactment intended to relieve agricultural debtors. The Court read section 3 along with sections 6 and 13 of the Act and considered the legislative history, including the amendment extending the filing period from 1 October 1969 to 1 April 1970. In that context, the word "before" was held to be ambiguous and capable of meaning "upto" or "not later than", rather than excluding the specified date. On that construction, an application made on 1 April 1970 was treated as filed within time. In view of this conclusion, it was unnecessary to decide whether section 5 of the Limitation Act, 1963 applied to proceedings under section 3.

Conclusion: The application filed on 1 April 1970 was within the prescribed time under section 3 of the Act.

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