Exhaustive character of statutory definitions preceded by means and includes

When a statutory definition clause in an enactment utilizes the phrase "means and includes", as seen in Section 2(1)(e) of the Arbitration and Conciliation Act, 1996, the definition is exhaustive. The legislature intentionally marks out specific forums—the Principal Civil Court of original jurisdiction and High Courts with ordinary original civil jurisdiction—to the exclusion of all other judicial bodies. Courts cannot expand or alter such exhaustive statutory definitions unless the context imperatively and unambiguously demands a departure. Perceived practical inconvenience or subjective notions of court hierarchy do not constitute sufficient contextual justification to override an exhaustive definition. Departures from defined statutory terms must be anchored in compelling legislative context rather than judicial preference. Consequently, courts subordinate to the Principal Civil Court or High Courts without original civil jurisdiction remain strictly excluded from exercising jurisdiction under Part I provisions. (Jagdeep Chowgule v. Sheela Chowgule & Ors. | 2026 INSC 92)