In Commissioners of Customs and Excise v. Savoy Hotel Limited (1966) 1. W.L.R. 948 at 954, Sacks, J. stated: "'Including' is a word to which parliamentary draftsmen seem to be considerably addicted: One reason for this may be that in law it can have, accordingly to its context, not only one or other of simple but in essence quite differing effects (for instance, in relation to the words that follow it may be found to have been used simply to enlarge, to limit, to define exhaustively, or for the avoidance of doubt to repeat the preceeding word or phrase), but it may also be used to secure on one and the same occasion more than one of those effects, thus putting the draftsmen, but not necessarily the court in a happy position."
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