How have statutory headings been interpreted in the context of statutory construction?

Canada (Federal), Canada

The following excerpt is from Skoke-Graham v. The Queen, [1985] 1 SCR 106, 1985 CanLII 60 (SCC):

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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