The third general approach to statutory interpretation is set out in Grey v. Pearson (1857) 6 HLC 61. This approach, the so-called "golden rule" reflected a tempering of the literal approach and resulted from the judicial realization that the bulk of statutory material and the increasing complexity of statutes would occasionally produce errors in drafting leading to inconsistency, conflict and internal disharmony. Hence the "golden rule" counselled judges to give language its ordinary meaning unless inconsistency, absurdity or disharmony would result.
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