He does contrary to the law who does what the law prohibits; he acts in fraud of the law who, the letter of the law being inviolate, uses the law contrary to its intention.

Explanation

Compliance with the letter of a statute while subverting its purpose is as unlawful as open violation — cite this against schemes that technically satisfy statutory language but defeat the law's protective intent.

Where this applies

• A company structures a transaction to technically comply with a tax statute while completely defeating its purpose of preventing hidden offshore profits, and the court treats the scheme as fraud upon the law.
• A contractor follows the literal wording of a building code but uses materials and methods that make the structure unsafe, violating the code's purpose of protecting occupants, and the court holds this is acting in fraud of the law.
• A landlord complies with the letter of an eviction statute by giving notice but times the notice to fall during a holiday when the tenant cannot respond, circumventing the law's intent to give tenants a fair chance to be heard.