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Microlesson · 5-min read

Duty to be Taken Pro Rata; Gender and Number (Sections 12 and 13)

# Sections 12 and 13 — Pro Rata Duty; Gender and Number

## Section 12 — Duty to be taken pro rata

Where any duty of customs or excise (or duty of a similar nature) is leviable on a given quantity by weight, measure or value of any goods or merchandise, a like duty is leviable at the same rate on any greater or lesser quantity.

### Plain-English meaning

The statutory rate scales proportionately up or down. A duty fixed for 1 kg becomes 5 × that duty for 5 kg, and half of it for 500 grams.

### Illustration (from the syllabus)

If a company has 100 shares outstanding and declares a dividend of ₹2 per share, the total dividend pool is ₹200. Each shareholder receives a pro rata share of that pool based on their holding. The total cannot exceed ₹200 — and the per-shareholder amount is calculated proportionately.

(The Section is primarily about customs/excise duty, but the pro rata concept it embeds applies wherever statute uses a rate-based levy on quantity.)

## Section 13 — Gender and number

In all Central Acts and Regulations, unless context requires otherwise:

1. Words importing the masculine gender shall include females.

2. Words in the singular shall include the plural, and vice versa.

So if a statute uses 'he', it normally also covers 'she'; if it uses 'company', it can cover 'companies'.

### Crucial qualifications

  • Succession law caution: The rule is applied carefully in succession matters. Courts have held that 'male descendants' does not automatically include female descendants — the social and legislative context is heavily weighted.
  • Gender-specific statutes: If an Act is meant for a specific gender (e.g., the Maternity Benefits Act), the gender-neutralising rule does not apply.
  • Specific-gender words override the presumption: Where a common-gender word exists but the legislature has consciously used a specific-gender term, the General Clauses presumption is rebutted. Hence the word 'bullocks' has been held not to include 'cows'.

Worked example

### Example 1

Q: A statute imposes excise duty of ₹100 per kg of a product. A consignment of 2.5 kg is imported. What is the duty?

A: Under Section 12, duty scales pro rata: ₹100 × 2.5 = ₹250.

### Example 2

Q: A penal provision states 'whoever does X shall be liable to fine'. A woman commits the act. Can she be prosecuted?

A: Yes. Section 13(1) treats masculine words as including the feminine, so 'whoever' covers a woman equally.

### Example 3

Q: A succession statute refers to 'male descendants'. Can the rule of Section 13 expand this to female descendants?

A: No. Courts apply Section 13 cautiously in succession contexts. 'Male descendants' has been held not to include female descendants — the specific-gender wording rebuts the presumption.

⚠️ Common exam mistakes

  • Mechanically applying Section 13 to read 'he' as 'she' in succession laws — courts have refused this extension where the statute uses gender-specific words.
  • Forgetting that Section 13 is subject to 'unless context requires otherwise' — gender-specific statutes (e.g., Maternity Benefits Act) operate within their declared scope.
  • Treating Section 12 as a general rule for all taxes. It specifically speaks of customs/excise duty 'or in the nature thereof', although the pro rata logic is broadly applied.
Bare-Act text Sections 12 and 13 · The General Clauses Act, 1897 · click to expand
Section 12: Where, by any enactment now in force or hereafter to be in force, any duty of customs or excise, or in the nature thereof, is leviable on any given quantity, by weight, measure or value of any goods or merchandise, then a like duty is leviable according to the same rate on any greater or less quantity. Section 13: In all Central Acts and Regulations, unless there is anything repugnant in the subject or context — (1) words importing the masculine gender shall be taken to include females, and (2) words in the singular shall include the plural, and vice versa.
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