Many statutes are passed by parliament each year. The meaning of the law in these statutes should be clear and explicit but this is not always achieved. This is because laws must be drafted in general terms and must deal with both present and future situations. Often, a law which was drafted with one particular situation in mind will eventually be applied to quite different situations. Legislation is drawn up by draftsmen, and a draftsman’s capacity to anticipate the future is limited. He may not foresee some future possibility, or overlook a possible misinterpretation of the original intentions of the legislation. Another problem is legislation often tries to deal with problems that involve different and conflicting interests. Both legal and general English contain many words with more than one meaning. In fact, some of the broad terms are used which have seven or more distinct definitions. With this being the case, even the best drafted legislation can include many ambiguities. This is the fact where people look at a text from different points of view they will naturally find different meanings in the language used. The courts are helped by a number of tried and tested rules of statutory interpretation. Judges have their own preferences as to these rules and are free to choose which approach to adopt depending upon the circumstances. The first option open to the judge is literal rule which involves applying the 'plain, ordinary, literal meaning’ of words even if this would lead to a manifest absurdity. This rule has been widely used even though the results have made nonsense of the law. This is illustrated in the case of Whitely v Chappell [1868] where it was held that the defendant was not guilty since a dead person is not, in the literal meaning of the word, "entitled to vote". This rule has also bought about harsh decisions due to the way it is applied. In