Can section headings be used as a guide to interpretation of a statute?
British Columbia, Canada
The following excerpt is from Schoenhalz v. ICBC, 2016 BCSC 661 (CanLII):
…that section headings can be used as a guide to interpretation of a statute (Law Society of Upper Canada v. Skapinker, 1984 CanLII 3 (SCC), [1984] 1 S.C.R. 357 at 13-14, 9 D.L.R. (4th) 161). Both parties further agree that the legislative history of the appeal provisions of the Act is the most effective guide to the task before me; however they disagree as to the correct interpretation of that history.
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