Vanderbilt Law Review

First Page



The Supreme Court of Tennessee reconsidered several problems in the field of Statutory Interpretation during the Survey period, but its decisions largely followed principles already established in Tennessee and other jurisdictions.

Constitutional Requirements

Certain problems in the field of legislation arise in Tennessee by reason of state constitutional provisions. The Court is committed to the position of interpreting these provisions more or less irrespective of the construction of comparable provisions in other state constitutions.'

The Constitution of the State of Tennessee provides: "No bill shall become a law, which embraces more than one subject; that subject to be expressed in the title." A chief justice of the Tennessee Supreme Court who was a member of the constitutional convention of 1870 which drafted this provision has explained its purpose: "The Convention evidently designed to cut up by the roots, not only the pernicious system of legislation, which embraced in one act incongruous and independent subjects, but also the evil practice of giving titles to acts which conveyed no real information as to the objects embraced in its provisions." The title of a statute may be either narrow and restricted or broad and general, as the legislature may determine. In either case, if the legislation under the title is germane to the general subject, it is not invalid under the one-subject provision. If the title is general, it justifies provisions in the body of the statute not incongruous with its provisions as to the manner, means and instrumentality whereby it may be enforced or its purpose accomplished.