Partington v AG [1869] LR 4 HL 100

Lord Cairns LC

• If the subject comes within the letter or the law he must be taxed, however great the hardship may appear to be.

• On the other hand, if the Crown, seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of the law the case might otherwise appear to be.

• If there be admissible, in any statute, what is called an equitable construction, certainly such a construction is not admissible in a taxing statute, where you can simply adhere to the words of the statute.