Summary of Issue: Context And Titles

Decision A-0094.94 Full Text of Decision A-0094.94

The heading preceding ss. 12(1) is "Income Benefit" while the heading preceding ss. 13(1) is "Benefit If No Income". It is now well settled that, unlike marginal notes, headings may be used as aids to the construction of the language of an enactment.

Decision 23985 Full Text of Decision 23985

Refer to: A-0094.94

Decision 21630 Full Text of Decision 21630

Refer to: A-1393.92

Decision A-1393.92 Full Text of Decision A-1393.92

We agree that legal interpretation entails consideration of numerous factors, and it may be necessary to ignore the restrictive view suggested by the immediate context if a more liberal approach is dictated by Parliament's overall intent. Today there is only one principle or approach, namely, the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament. As stated in GARLAND, it is necessary to read the statute containing the words in issue in its entirety as an initial step. Only after that has been done can it be determined with any precision whether or not the words being interpreted are clear and unambiguous. We accept this approach.

Decision 20498 Full Text of Decision 20498

It is clear from the context that ss. 43(3) has to do with self-employed farmers: the section appears under the heading "Self-Employed Person". Also, ss. 43(1) expressly deals with self-employed persons and ss. 43(2) and (3) deal with specific categories of self-employed.

Decision A-0637.86 Full Text of Decision A-0637.86

It seems appropriate to me that the provisions concerning entitlement be interpreted liberally following ABRAHAMS. Nevertheless, Part V of the Act [s. 120] does not deal with entitlement but with the administrative mechanism. No need for liberal interpretation. [Dejardins, J.]

Decision A-0451.85 Full Text of Decision A-0451.85

A word in a statute is a cell within an organism, an incomplete structure within a more complete one, and can be fully understood only in relation to the whole of which it is a constituent part. [Justice MacGuigan] The words must be read in their entire context [s. 32] and in their grammatical and ordinary sense harmoniously with the scheme, the object and the intention of the Act. Part I is entitled UI Benefits and encompasses s. 5 to 44.

Decision A-1132.84 Full Text of Decision A-1132.84

The words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the object of the Act. If the words are clear and unambiguous they must be followed. [p. 7-8]