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Microlesson · 5-min read

'Shall' vs 'May' — Mandatory and Directory Provisions

# 'Shall' vs 'May' in Statutes

## The Basic Rule

WordPresumption RaisedNature
ShallSomething is mandatory / imperativeCompulsory — must be followed
MaySomething is directory / enablingOptional — provides power or option

## Why is this important?

The difference between mandatory and directory provisions has serious legal consequences:

  • Mandatory ('shall'): Non-compliance leads to invalidity of the act
  • Directory ('may'): Non-compliance may not invalidate the act

## Important Caveat — Context Matters

The rule is a presumption, NOT absolute. Sometimes:

  • 'May' has to be read as 'Shall' (mandatory)
  • 'Shall' may have to be read as 'May' (directory)

The true test is the intention of the legislature and the context in which the word is used.

## Example: Section 3 of the Companies Act, 2013

> "A company may be formed for any lawful purpose by ..."

At first glance, 'may' suggests an option. But in this context:

  • A company cannot be formed for an UNLAWFUL purpose
  • The requirement is mandatory
  • Therefore, 'may' here is read as 'shall' for the purpose of legal formation

Usage of 'may' here makes it mandatory for a company to comply with Section 3 for its formation.

## Practical Tests to Distinguish

When reading a statutory provision, consider:

1. What is the object of the Act?

2. What was the intention of the legislature?

3. What are the consequences of non-compliance?

4. Does treating it as directory defeat the purpose of the provision?

If treating 'may' as optional defeats the purpose → read as 'shall'

If treating 'shall' as mandatory leads to absurd results → may be read as 'may'

## Summary

> 'Shall' = generally mandatory

> 'May' = generally directory

> But always check legislative intent and context

Worked example

### Example 1

Q: Section 3 of the Companies Act, 2013 states that 'A company may be formed for any lawful purpose...'. Is the formation requirement optional or mandatory?

A: Although 'may' is used, here it must be read as 'shall' because the legislative intent is that compliance with Section 3 is mandatory for formation of any company. The word 'may' provides the choice of forming a company; once chosen, the requirements are compulsory.

### Example 2

Q: A statute says 'The Registrar shall register the document within 7 days.' What is the effect of using 'shall'?

A: The use of 'shall' raises a presumption that the requirement is mandatory/imperative. The Registrar is under a duty to register the document within 7 days. Whether non-compliance invalidates the registration depends on whether the provision is held to be mandatory or directory in light of the legislative intent.

⚠️ Common exam mistakes

  • Applying the 'shall = mandatory' rule mechanically without examining legislative intent
  • Assuming 'may' is always discretionary
  • Ignoring the context and purpose of the provision
  • Not appreciating that the test of mandatory/directory depends on consequences of non-compliance
Reference:
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