Notwithstanding, the implication of the foregoing is that first and foremost the literal rule must be applied.
But the literal rule has its obvious limitations in that in a lot of cases the object of the legislation suffers in deference to its literal interpretation.
In the most strident criticism of the Literal Rule, Professor H.L.A.
Yet, dubious as this sounds, the proponents of the Literal Rule continue to trumpet that it promotes certainty of the law.
In conception then the rule was never meant to be independent of but supplementary to the Literal Rule.
Lord Esher's famous dictum (52) is often put forward as a flag waving proposition for the Literal Rule. In his words: "If the words of an Act are clear, you must follow them, even though they lead to a manifest absurdity.
Though the Mischief rule was the earliest rule of interpretation historically the literal rule came to be mentioned as the rule and the mischief rule as the exception to it.