Pepper v Hart [1993] AC 593

Court: House of Lords

Facts: Teachers, including Hart, at a private school were offered reduced-rate education for their children. The Inland Revenue assessed this as taxable based on the average cost of education, while Hart argued for marginal cost taxation. He sought to use Hansard, the record of Parliamentary debates, to support his interpretation of the Finance Act 1976.

Issue: Can courts refer to Hansard when interpreting ambiguous legislation?

Held: The House of Lords allowed reference to Hansard where the legislation is ambiguous, obscure, or leads to absurdity, provided the ministerial statements in Parliament are clear. This marked a departure from previous rules prohibiting such references.

Key Judicial Statement: Lord Browne-Wilkinson clarified that using Hansard to understand legislative intent respects the integrity of Parliament and aids judicial interpretation, without infringing on Parliamentary privilege.

💡Leveluplaw: Courts may now use Parliamentary debates (Hansard) to interpret ambiguous legislation, offering a clearer understanding of statutory intent.