Can section headings be interpreted as a valid indicator of legislative intent?

British Columbia, Canada


The following excerpt is from Svangtun v Pacific National Exhibition, 2019 BCSC 121 (CanLII):

VCHA submits that every enactment must be given a fair, large and liberal interpretation to ensure the achievement of its objectives. It submits that section headings can be used as a guide to interpret a statutory provision and should be read and relied on like any other contextual feature as a valid indicator of legislative intent: Arts Umbrella v. British Columbia (Assessor of Area 09 - Vancouver), 2007 BCCA 45 at para. 3 and Jacob v. Laumaillet, 2010 BCSC 1229 at paras. 31-32. The section heading to s. 91 – “Confidentiality of Personal Information” – indicates clearly that the intent of s. 91(2) is to protect personal information, not just evidence about it.

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