shall

Providing generally, but not always, a mandate, where appearing in a constitutional provision. 16 Am J2d Const L § 92. Ordinarily, a word of mandate, the equivalent of "must," where appearing in a statute. Stanfield v Willoughby (Ky) 286 SW2d 908, 53 ALR2d 925; State ex rel. McKittrick v Wymore, 343 Mo 98, 119 SW2d 941, 119 ALR 710; Saba v Homeland Ins. Co. 159 Ohio St 237, 112 NE2d 1, 44 ALR2d 841. Construed as "must" in a statute providing for increased punishment for a subsequent offender. People v Gowasky, 244 NY 451, 155 NE 737, 58 ALR 9. Sometimes meaning "may," as where used in a statute providing that when property owners petition for the improvement of a street, the municipal authorities "shall" cause the work to be done. Rockwell v Junction City, 92 Kan 513, 141 P 299. The word "shall" may be held to be merely directory when no advantage is lost, when no right is destroyed, when no benefit is sacrificed, either to the public or to any individual, by giving it that construction. Montgomery v Henry, 144 Ala 629, 39 So 507.