How have courts interpreted a heading in the Canadian Charter of Rights and Freedoms?

In Law Society of Upper Canada v. Skapinker (1984), 1984 CanLII 3 (SCC), 9 D.L.R. (4th) 161, 11 C.C.C. (3d) 481, 53 N.R. 169 (S.C.C.) Estey J. considered a heading in the Canadian Charter of Rights and Freedoms in interpreting a section of the Charter. He said [at p. 177 D.L.R., pp. 193-4 N.R.]: For the purpose of examining the meaning of the two paragraphs of s. 6(2), I conclude that an attempt must be made to bring about a reconciliation of the heading with the section introduced by it. If, however, it becomes apparent that the section when read as a whole is clear and without ambiguity, the heading will not operate to change that clear and unambiguous meaning. Even in that midway position, a court should not, by the adoption of a technical rule of construction, shut itself off from whatever small assistance might be gathered from an examination of the heading as part of the entire constitutional document. This general approach I take to be consonant with the thinking expressed in the Canadian, British and United States authorities and texts discussed above.