Samarawickrema v. Commissioner of Excise and Others – sllr 1991 volume 1 page 209

In the case between Samarawickrema and the Commissioner of Excise and Another, the court addressed the issue of whether the confiscation of a parked lorry loaded with illicit liquor was valid under section 54(2) of the Excise Ordinance, particularly focusing on the interpretation of “used in carrying.” The court held that a vehicle need not be in motion to fall within the ambit of “used in carrying” excisable goods; the presence of articles loaded into a vehicle sufficed, even if static at the moment of detection. The holding reaffirmed the principle that statutory phrases must be construed in light of the statute’s purpose, rejecting a narrow technical approach. This decision relied on statutory interpretation, dictionary definitions, and the precedent of Renton & Co. Ltd. v. Palmyrah Tra