R.M.D. Chamarbaugwalla v. Union of India

This case explains how to read the Prize Competitions Act, 1955. The Supreme Court said the Act is meant to control gambling-type competitions. If a contest mainly needs skill, it is not the target of this law. The Court also said that gambling is not trade, so it does not get protection under Article 19(1)(g). If any part of the Act is over-broad, the valid part can still work because of the doctrine of severability.

• Does the Act’s term “prize competition” include skill-based competitions?
• If skill contests are included, does that violate Article 19(1)(g) (freedom to carry on business)?
• If some parts are invalid, can the rest survive under the principle of severability?

• Heydon’s Rule: Look at (a) the law before the Act, (b) the mischief, (c) the remedy chosen by Parliament, and (d) the reason for that remedy.
• Aim, scope, object, intent: Read words in light of the Act’s purpose.
• Severability: If some provisions are unconstitutional, cut them out and give effect to the rest that is constitutional.

• The term “prize competition” in the Act refers to gambling activities, not contests mainly of skill.
• Gambling is not “trade”; it falls outside Articles 19(1)(g) and 301.
• Severability applies: even if the Act is read widely, only the part valid for gambling competitions will stand.
• Petitions were dismissed with costs.

The Court read the Act in line with its object: to control chance-based competitions. Using Heydon’s rule, the Court found the mischief was gambling, so the remedy was aimed at gambling. Thus, skill-based contests are outside the Act. Also, gambling is not trade, so fundamental business rights do not apply.

• Sets the skill vs chance line for contests and games.
• Confirms severability to save workable parts of laws.
• Clarifies that gambling lacks Article 19(1)(g) protection.
• Guides modern questions on quizzes, fantasy sports, and online games.

Mnemonic: S-C-S → Skill out, Chance in, Sever the rest.

1. Skill out: Skill-focused contests are beyond the Act.
2. Chance in: Gambling-type contests are within the Act.
3. Sever rest: If any part overreaches, apply severability.

Issue: Scope of “prize competition”; Article 19(1)(g); severability.

Rule: Heydon’s rule; purpose-based reading; severability doctrine.

Application: The mischief was gambling. The Act’s limits fit chance-based contests, not skill contests. Even if broad, valid parts can be saved.

Conclusion: The Act applies to gambling competitions. Skill-based contests are outside. No Article 19(1)(g) protection for gambling. Petitions dismissed with costs.

Heydon’s Rule

Method to find the law’s purpose by seeing the mischief and remedy.

Severability

Cut off invalid parts; keep the valid parts of a statute.

Prize Competition

Here, read as chance-based competitions targeted by the Act.

• State of Bombay v. R.M.D. Chamarbaugwala — skill vs chance line in competitions.
• K.R. Lakshmanan v. State of Tamil Nadu — horse racing as a game of skill.
• Modern decisions on fantasy sports (skill-dominant analysis).