39. The role of headings in statutory construction has been thoroughly canvassed by Mr. Justice Estey in Law Society of Upper Canada v. Skapinker, 1984 CanLII 3 (SCC), [1984] 1 S.C.R. 357. Estey J. noted that neither the Canadian, English, nor American jurisprudence expresses any definite canon of construction applicable to statute headings.
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