Different Schools Of Statutory Interpretation

Different Schools Of Statutory Interpretation
Introduction and Thesis There are multiple schools of thought when it comes to how courts should interpret statues and legislation, some schools
advocate a literal, textual reading of the relevant statues, while other schools advocate taking other factors into account when making a decision, factors
like the intent of the legislature when they passed the statue. The case AA v BB provides a good look into the issue of statutory interpretation because
the two different courts that heard the case applied a different from of statutory interpretation. The lower court stuck to a textual interpretation, whereas
the court of appeal considered the legislative intent behind the relevant statues. This paper will argue that of the two schools of statutory interpretation
applied in the case, textualism and intentionalism, neither is completely appropriate and that the pragmatic approach to statutory interpretation is the
most appropriate method to use. It will then argue that the decision by the Ontario Court of Appeal in AA v BB is the more convincing decision as it
best aligns with the pragmatic approach.
Point I: Why the pragmatic approach is more appropriate than a strictly textualist or intentionalist approach.
Textualism is a school of statutory interpretation that relies on the text of the statue to determine the true intent of the legislature. Textualism is heavily
reliant on the "plain meaning rule," which essentially means that when the text of a statue is clear and
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Statutory Interpretation Essay
Assignment 01
Introduction
The enactment of both the interim and final Constitution ushered in a new approach to statutory interpretation. In this essay I argue that the statement
made by the court in Daniels v Campbell 2003 (9) BLCR 969 (C) is true.
The interpretative approach adopted by South African courts pre–1994
Statutory interpretation pre–1994 lacked a single theoretical starting point.
There was no single methodology that was applied to interpret legislation.
Consequently the process of interpreting legislation involved a mixture of theoretical approaches that were often conflicting and inconsistent.
One of the theoretical approaches that were used pre–1994 was the text–based approach. The text–based approach accords the...show more content...
This inevitably means that extra–textual factors are being considered before the legislative text is considered in its literal grammatical sense.
The Constitution imposes a single theoretical starting point in interpreting legislation. This was made clear by Ngcobo J in the Bato Star Fishing (Pty)
Ltd v
Minister of Environmental Affairs and Tourism 2004 (4) SA 490 (CC):
The Constitution is ... the starting point in interpreting any legislation. ... first, the interpretation that is placed upon a statute must, where possible, be
one that would advance at least an identifiable value enshrined in the
Bill of Rights; and, second, the statute must be capable of such interpretation... The emerging trend in statutory construction is to have regard to the
context in which the words occur, even where the words to be construed are clear and unambiguous.
Post 1994 the Constitution is the supreme law of the land consequently it makes demands on the interpretation of legislative text. The Constitution
needs to be applied in all courts in interpreting legislation to give effect the concept of the
Constitutional state. However there are still instances where courts use a hybrid
approach in interpreting legislation. For example in Shackleton Credit
Management (Pty) Ltd v Scholtz the court outlined three interpretation approaches: 1. The golden rule (the plain meaning of the text must be followed
unless it leads to an absurdity or a result not intended by the legislature);
2.

The Value Of Peace Of Mind Essay
There are many different interpretations of the word "need" and how it can be used in conversation. Need is a general term but can encompass
peace of mind, human companionship, feeling as if you need a material item, bare necessities, or feeling like you're in control of your health and
mind. Need can be influenced by the culture a person grew up in, how they were raised to be by their parents (or lack of), and society's view of how a
person should be. All of the definitions of the word "need" interconnect with one another to form a much broader definition. Peace of mind is a human
need, regardless of whether people deem it to be or not. The majority of people like to feel emotionally stable and can achieve this through job
security. If one is worrying over the state of how much work they have to do or whether or not they can support themselves, they tend to be unhappy.
While happiness isn't a requirement for living, most people see it as the point of their existence. Who wants to go through all of the bad in life without
the good to help them through? Another aspect of peace of mind is self – esteem. Many humans develop eating disorders such as bulimia, anorexia, or
body distortion due to the negative way they think of their body. Self – esteem can additionally be impacted by a person's mindset, which can be
wrecked due to depression or other issues of the mind. Without self – esteem, people can feel as if they're unnecessary to the world going on around
them. Human

Case Study: Statutory Determinations
Statutory Determinations Based on information currently available, the EPA believes the Preferred Alternative (Alternative 2) meets the NCP
threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. EPA
expects the Preferred Alternative to satisfy the following statutory requirements of CERCLA В§121 (b): (1) be protective of human health and the
environment; (2) comply with ARARs; (3) be cost–effective; and (4) utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Though Alternative 2 does not meet the statutory preference for treatment, this Proposed
Plan explains why that preference

The Interpretation Of Statutory Interpretation
Driedger 's modern approach to statutory interpretation has substantially impacted the comprehension of ambiguous statutory language in Canadian
courts for several decades. Although there are some drawbacks and flaws in this method, there is a myriad of merits that have positively shaped the
interpretation of ambiguous statutory language over the years. When adjudicators are faced with the challenging task of analyzing unclear legislative
text, they are obligated to utilizing Driedger 's modern approach to statutory interpretation. If it were not for this approach, the elucidation of equivocal
legislative text in legal proceedings would have been entirely disparate and there presumably would have been more discrepancies, inconsistencies, and
controversies over judges ' pivotal decisions made in Canadian courts. Driedger 's modern approach to statutory interpretation provides judges with
discernment, guidance, and insight when making crucial decisions. Evidently, this strategy has facilitated decision making for judges and has
considerably availed them during times where ambiguous statutory language has been a paramount impediment in judicial proceedings. One of the
merits of Driedger 's modern approach to statutory interpretation includes the authorization of judges to explicate legislative text after analyzing the
simple meaning of the text. Every individual should find the plain meaning of the legislative text to be identical as law is intended to be dependable and

Question 1
Introduction
A statute is the formal and the written law of the country. It is passed by the legislative authority of the country. Generally, statutes, and, prohibit or
declare something and sometimes, they are also called as legislation. In this way, statutory interpretation means the interpretation of the statutes by the
courts. This interpretation takes place when an Act of the Parliament is not clear and as a result, it creates uncertainty in the law. Therefore,statutory
interpretation is required when an Act passed by the Parliament is not clear, for example a term could have been used to covers a number of
opportunities. Similarly the meaning of a term can also change its meaning over the period of time which results in...show more content...
In this case, the defendant was a shopkeeper and had placed a flick knife along with its price in the window of his shop although no flick knife was
sold by the shopkeeper. In this regard, the defendant was charged under section 1(1) of the Registration of Offenses Weapons Act, 1959 according
to which any person who sells, hires or offers for sale any flick knife will be guilty of the offense. However in this case, the court was required to
decide if defendant had committed the offense of offering the knife for sale. Offer has been given a technical legal meaning by the law of contract. In
this regard, the contract law provides that is playing an article in shop window cannot be considered as an offered by it is only an invitation to treat
(French, 2011). In this way, by adopting the literal approach of statutory interpretation, the court decided that the shopkeeper was not guilty of offering
the flick knife for sale.
Application
In order to decide if the offense prescribed by the Registration of Offenses Weapons Act, 1959 has been committed in these three scenarios or not, the
literal, golden or the mischief rule of statutory interpretation has to be applied (Australian Law Students Association, 2009).
Scenario 1
In this case, Jane had confiscated a flick–knife from a member of the youth club and had given the same to her supervisor. In this regard, by applying
the mischief rule of statutory interpretation,

'There is, in fact, no such thing as judge–made law, for the judges do not make the law, though they frequently have to apply existing law to
circumstances as to which it has not previously been authoritatively laid down that such law is applicable'. Lord Esher MR in Willis v Baddeley
[1892] 2 QB 324 (CA) 326 With reference to the rules of Statutory Interpretation and the doctrine of judicial precedent, discuss the extent to which you
agree or disagree with this statement. CONSIDER STATUTORY INTERPRETATION ONLY FIRST 1000 WORDS IN structure; Introduce statutory
interpretation, Explain it – 3 riulesm aids etc Explain as you go alon which is for which is against, evaluate these Arguments for: Only apply existing
law to cases Statutory Interpretation; intrinsic and extrinsic aids and rules to follow to interpret statues – no judicial law making. Though they apply
existing law, due to ambiguity in statutes or languae used – can be out of date, attitudes have changed, interpret statutes in different ways could lead to
2 different decisions on the same case, no scientific formula or consistency and precison in interpreting statutes– the rules leave too much to the judges
own interpretation which may not be taking into account the intention of parliament – effectively creating new law? Within the Separation of powers
in the UK, Parliament (the legislature) make the law via statutes, and the Courts (the judiciary) interpret these statutes and apply the law

Introduction
In South Africa, the courts make use of two main theories and approaches applicable for the interpretation of legislation which are the orthodox
text–based approach and the text–in–context approach . The approach which will be discussed below is the orthodox text–based approach and
alongside the influence of the supreme Constitution on the interpretation of legislation. The case provided for the orthodox text–based approach is the
matter concerning Ngwenyama v Mayelane & another. For the influence of the supreme Constitution on the interpretation of legislation the case
concerning Road Accident Fund and Another v Mdeyide will be discussed. By doing this, it makes it possible to witness and understand how
legislation is interpreted...show more content...
Mr Mdeyide only put in a claim for the compensation of the accident in terms of the Road Accident Fund Act with the Road Accident Fund three years
and three days after the accident.
Legal question:
Does the Road Accident Fund and the Minister of Transport have the right to limit access to courts and deny the right to claim for compensation?
Judgement:
The court ruled that the limitations set out within the provision provided by the Road Accident Fund is unconstitutional and that the prescribed period
to claim is too inflexible and therefore cannot be justified.
Interpretation:
As stated above the Constitution is the highest law of the land therefore everything and everyone is subject to it. Any law or conduct that goes against
it is seen as invalid. The influence of the constitution in this case can be seen as the Road Accident Fund Act goes against sections of the Constitution
and the Prescription

TRADITIONAL RULES OF STATUTORY INTEPRITATION
LEGAL RESEARCH AND WRITING II
LAW 108
when parliament has exceeded a certain stage, it falls to the court to apply the statute in a particular case. This can lead to hardship in the sense that the
fact of certain issues may not have been concluded by the parliament or where right are been moved as an error in the statute.
The three traditional rules of statutory interpretation are:
1 THE LITERAL RULE
2 THE GOLDEN RULE
3 THE MISCHIEF RULE.
THE GOLDEN RULE
The golden rule seems to have been originated in an 1854 court ruling, and shows a degree of enthusiasm for this...show more content...
Advantage and disadvantage of the golden rule
1: The main advantage of the golden rule is that raising mistakes and statutes can be corrected immediately. This is seen in the (R V ALLEN)1872
case where the loopholes where closed the decision was in line with parliament intentions and it gave a more just outcome
2: the main disadvantage of the golden rule is that judges can technically and wisely change the law by exchanging the meaning of words in the statute
. the can potentially infringing the separation of power between legal and legislature.

The golden rule would help if there is no absurdity in the statute. For example the London and northeastern railways V BERRIMAN 1946 CASE
Where the widow couldn't get compensation because the wording of the statute didn't allow for the circumstances or the situation.
THE LITERAL

Statutory interpretation refers to an action of a court in trying to understand and explaining the meaning of a piece of legislation. People do not know
the importance of the statutory interpretation. However, the law of interpretation status is the most substantial side to practice legality, and it will
always remain important to conclude the aim of statutory interpretation, the statutory Interpretation includes 3 rules; The literal rule, the golden rule,
and the mischief rule.
The literal rule is one of the main type of statutory interpretation which tell that it should be interpreted using ordinary meaning of the language, It
modify word by word. The words of an act are clear, the court has nothing to do, you have to respect the rule even if the rule does not make sense.
The literal rule is the first rule that was applied by the judges. There are a lot of disadvantages in the literal rule, one of the main disadvantage is that
the judges are entitled to change the rule it also provides no scope for judges to use their own opinions and because of that lots of problems are found
in the literal rule, the main problem is that there can be disagreements as to what amount to the ordinary, it also creates deception in the law.
The golden rule Is the modification of the literal rule, it looks at the literal meaning, they look at a more appropriate word, after the golden rule it is
followed up with the mischief rule, this rule gives the judge more discretion than the other

Rules of Statutory Interpretation
UNIVERSITY OF NAIROBI, SCHOOL OF LAW GPR 109: LEGAL SYSTEM AND METHOD LEGAL METHOD TAKE AWAY CAT
NKARICHIA MUGAMBI DENNIS G34/3053/2013
Q; there are some rules of language' used by courts and the legal profession in studying or interpreting written law. They are more of rules of practice
than legal rules.
Outline the most common of these and give a brief commentary or explanation of the same.
RULES OF LANGUAGE IN STATUTORY INTERPRETATION
.
The traditional common–law approach to statutory interpretation was to "look at the words of the Act". This approach was founded on the assumption
that the statute alone was a reliable guide to the intent of the Parliament. To assist the courts in interpreting legislation, judges...show more content...
(iv) The intentions appear to be not different from the construction of noscitur a sociis being given to the associated words.
In Inland Revenue Commissioners v Frere, it was held that 'interest' meant annual interest. If there had beenomission of the words – 'other annual
interest' –then the word interest could have meant any interest – weekly, monthly and so on.
Also in Muir v. Keay the Refreshment House Act stated that 'houses, rooms, shops or other building kept open for public refreshment and
entertainment must be licensed.' A cafГ© even though not playing music nor having dancing taking place was held to be a place for entertainment as
its patrons were supplied with beer, cigars and coffee.
2.1 The sub–rule of Rank
It's a particular application of the maxim where a string of items of a certain level is followed by general words. In that case the assumption is that
the general words are not expected to include items of higher rank. In Gregory v. Fearn it was held that the string 'tradesmen, artificer, workman,
laborer, or other persons whatsoever did not include persons above the artisan class. 3 EXPRESSIO UNIUS EST EXCLUSIO ULLERIUS
Mention of one or more things of a particular class may be

'[t]he courts no longer approach a statute with scissors in one hand and a dictionary in the other'.
Critically assess the applicability of this statement as an analysis of the current approach of the judiciary to statutory interpretation in Australia.
Statutory interpretation is the legal process whereby a judge applies a statute to a case and must give meaning to the words in the statute in order to
decide what they mean and how it should be applied to a particular case. When interpreting statutes, the judges' role is to put into effect the Parliaments
wishes. Conflicts may arise when deciding if the intention of Parliament can be found in the words of the statute itself or whether judges should acquire
into the purpose of the Act then interpret the words themselves. In order to interpret these...show more content...
The Project Blue Sky case concerned the question of whether a program standard known as the Australian Content Standard made by the Australian
Broadcasting Commission was invalid. The invalidity alleged was that the Australian Broadcasting Commission gave preference to Australian
television programmes contrary to Australia's obligations under certain trade agreements.
The relevant Act contained an objects clause which specified the purpose of the Act, however, within the body of the Act there were two conflicting
provisions. There was no doubt the Australian Content Standard was authorised by the literal reading of the words of the relevant provision. However,
another provision which was inconsistent with that section made the literal meaning very doubtful.
The court observed that the 'legal meaning', i.e. meaning the legislature is taken to have intended, may not correspond to the literal or grammatical
meaning. As four justices put

Assignment 01
Unique Number: 870061
Gillian Dick
50223585
Table of Contents
IndexPage Number 1. Introduction3 2. The facts of the Public Carriers Association3 3. The orthodox text–based (literal) approach4–54. The purposive
(text–in–context) approach5–6 5. Section 39(2) and the purposive approach6–7 6. Conclusion7
Bibliography
1. Introduction In the Public Carriers Association judgment, the Appellate Division employed two different theories ofstatutory interpretation in order to
arrive at a just conclusion. From the court's judgment, it is evident that the orthodox text–based (literal) approach...show more content...
Public Carriers Association v Toll Road Concessionaries is a recent example of the textual approach as it was applied inSouth Africa in the apartheid
era. The court discovered that the words "road" and "alternative road" are not linguistically limited to a single ordinary grammatical meaning. The
phrase could mean either "a different roadway" (as the Association argued) or a different "route" (as the toll operators argued). It was found that none
of the recognised internal or external aids helped to determine which one of the two meanings of the term "road" was intended by the legislature. The
textual approach therefore did not provide any solution to the problem. (Study Guide 2009:34–35). In the Public Carriers and Association Case at pg
943, a judgment delivered in 1990, Smalberger JA stated that "the notion of what is known as a 'purposive construction' is not entirely alien to our
law". Botha states that "most of the courts still follow the traditional plain–meaning approach (Botha 2005:50). Smalberger JA preferred to follow the
literal interpretation principle as being entrenched in our law and stated "it must be accepted that the literal interpretation principle is firmly
entrenched ion our law and I do not seek to challenge it". He was of the opinion that it was only in cases of

The Significance Of Statutory Interpretation
Statutory interpretation can be required when there is complexity of uncertainty arises when judges interpret the law. There are several instances where
a judge may call for statues to be interpreted. For example, when there is failure in legislation on a particular point such as, change in the use of
language. When there is a form of ambiguity in the statue it can lead to a dispute. Mean a dispute can arise when a statue can have more than one
meaning which, could affect the outcome of a case dependent on which meaning they use to interpret the statue. However, statue in the 18th century,
used words which has different meanings. Which, was illustrated in the case of Cheeseman v DPP. The defendant was witnessed masturbating in public
toilet by the police officers. However, Under The Town Police Clauses Act 1847 , stated that they must be a passenger. On the other hand, The Public
Health Amendment Act 1902, stated that the word, 'street' could mean any public places under the control of local authority which were the police
officers. The Police Clauses Act stated the word, 'passenger' could have different meanings but, in this case they believed that it could mean a, 'foot
passenger' also, the police were not travelling at the time they saw the defendant and he could not be arrested under these circumstances. This shows
that there can be ambiguity interpreting statutes because, there was a form of lexical and structural ambiguity interpreting which resulted in a statutory

Both statutory interpretation and the Human Rights Act are a doctrine of precedent by which law is changed and justice is served. The doctrine of
precedent is an essential principle of English legal system, which is a form of reasoning, interpreting and decision making formed by case law. It
suggests that precedents not only have persuasive authority but must also be shadowed when similar situations arise. Any rule or principle declared
by a higher court must be followed in future cases. In short the courts and tribunals are bound within prearranged restrictions by prior decisions of
other superior courts. All the judges are also obliged to follow the set–up precedents established by prior decisions which is called Stare decisis.
Making decisions according to precedent helps achieve two objectives. Initially it aids to maintain a system of stable laws which gives predictability
to the law and affords a degree of safety for individual rights. Moreover, it ensures that the law progresses only in accordance with the developing
perceptions of the community. Therefore, it more accurately mirrors the morals and prospects of the community that we live in. Statutory interpretation
is required where complication and ambiguity arises as to what the section actually provides and to whom is within the provisions. There are
numerous occurrences where judges call for statues to be interpreted further in more depth; such as failure of legislation to cover a point, a broad term,
drafting

Can a corrective approach to Scrivener's Error find conceptual room in a formal textualist theory of statutory interpretation?
1. Introduction.
2. The incompatibility of correction in intent–skeptical textualism. i) A negative account approved: Siegel's axiom. ii) A positive account rejected:
Manning's attempt.
3. The incompatibility of non–intent–skepticism and faithful agency: a response to Ohlendorf.
i) Getting Raz wrong: a theory built on sand. ii) Getting Raz right: in support of skepticism.
4. Conclusion.
1.Introduction
This essay will conclude there is no conceptual room for a corrective approach to scrivener's error in a textualist theory of statutory interpretation. To
do so I will seek to establish two main premises, from which necessarily follows my conclusion: The first main premise states that an error cannot be
judicially corrected in an intent–skeptical theory of textualism. I will establish this by supporting Siegel's axiomatic rejection of correction and by
critiquing Manning's attempt to find justification for correction in textualism.
The second main premise states that conceptions of textualism that employ non–intent–skepticism in order to correct errors do so in contravention of
the core textualist principle of faithful agency: therefore non–intent–skeptical justifications are not rightly textualist. By way of example of the pitfalls
of attempting to reconcile non–intent–skepticism with faithful agency I will examine what I consider the most

Statutory Interpretation Of An Act Of Parliament
Statutory interpretation is a procedure executed by judges when understanding an Act of Parliament, which transpires when they are confronted with
new components of legislation including definitions which are not distinctly conveyed. The courts retain the responsibility when the implications of
that statute are ambiguous to ascertain Parliaments objectives on how the law should be applied. This essay will examine the approaches and
methodical rules which direct judges in the interpretation of statutes, referencing and scrutinising pertinent case law, with specific emphasis on R v
Bentham , whereby the wording within the legislation was deliberated by the House of Lords who eventually quashed the case. Furthermore, the essay
will analyse and explore additional instruments that assist courts with statutory interpretation in case like R v Bentham , which comprise of internal and
external aids.
Statutory interpretation consists of four approaches directing judges on interpreting legislation. The literal rule exercises standard meanings of words,
despite that it could result in absurd and injustice judgements, consequently the golden rule takes effect. This rule emerges from the literal rule, yet it
avoids absurdity. Furthermore, there is a rule that considers the 'mischief' Parliament proposed to address, which is the mischief rule and is the closest
rule to the purposive approach, a contemporary approach that entails judges determining what they understand what Parliament

Statutory Interpretation
Statutory interpretation is process of interpreting statutes by the judges. The definition of statutes have had very specific words but indeed the judges
would still need the statutory interpretation to help them. The reason of this, even how, the words in the statutes are specific but sometimes the words
contains ambiguity and vagueness in words. On top of that, each word could give us different meaning. For example, we can find in the Oxford
Dictionary where a word would contain at least one meaning. Hence, without the statutory interpretation, a lot of judges would have trouble in deciding
their judgments in deciding a case. This essay will analyse the four rules, intrinsic aids and extrinsic aids and presumptions in the interpretation...show
more content...
Instead of confining itself simply to the mischief which the statute was intended to correct, the court resolves ambiguities by reference to the statute's
overall purpose. Indeed, many modern statutes are not simply intended to correct mischiefs in the common law but have a wider social agenda. Under
the purposive approach the courts should try to give effect to this wider statutory purpose in interpreting ambiguous provisions in statutes. For the
purposive approach the example case can be Knowles v Liverpool City Council (1993). Knowles was employed by the Council and was injured at
work whilst handling a defective flagstone. He claimed damages from them under the Employers' Liability (Defective Equipment) Act 1969. The
Council claimed that they were not liable as a flagstone could not be "equipment" within the Act. The House of Lords held that it could. The purpose of
the statute was to protect employees from exposure to dangerous materials. The words "equipment" should be interpreted in this context. The Council
were therefore liable for Knowles' injuries (Paul, 2002).
To assist judges in interpreting statutes there exist various aids that they may refer to. Aids to statutory interpretation are divided into internal aids and
external aids. These are sometimes referred to as intrinsic aids and extrinsic aids to interpretation.
Intrinsic aids to interpretation are concerned, less with the overall approach to interpretation, and more with the

1)INTRODUCTION:
The enactment of both interim and final Constitutions ushered in a new approach to statutory interpretation. In this essay I argue that the statement
made by the court in Daniels v Campbell 2003 (9) BCLR 969 ( C ) at 985 is TRUE.
2)THE INTERPRETATIVE APPROACH ADOPTED BY SOUTH AFRICAN COURTS PRE
– 1994:
Before 1994 South Africa was a country based on Apartheid rules and regulations. The Parliament was the highest legislative body and it interpreted
laws as it pleased, mostly in favour of 'white Christians'. Any other race or religion was treated in an unfair and sometimes inhumane way. These laws
were mainly based on Roman–Dutch law and influenced by English law.
The Parliamentary Acts did not favour anyone but...show more content...
On 4 February 1997 the Constitution of the Republic of South Africa, 1996 came into operation (Here after referred to as The Constitution, 1996).
This meant that Parliamentary Sovereignty was replaced by a Constitutional Supremacy. A Supreme Constitution meant the highest law of the land.
From this day forward all nation including the parliament and Parliament Acts had to oblige to the Constitution. Any law, legislation, government or act
in conflict with the Constitution will be disregarded and seen as invalid. This also meant that courts were no longer influenced by the government.
However all the changes Islam as a religion is quite complex when it comes to equal rights. As a man had more superior rights than a woman and
was allowed to marry more than one wife . Polygamous marriages were still not seen as morally acceptable so the death of a spouse or the inheritance
for a child from a polygamous marriage made things difficult .
However regarding case Daniels v Campbell on appeal to the Constitutional Court, Sachs J held that the word "spouse" in its ordinary meaning
includes parties to a Muslim marriage. Accordingly, it was not necessary to read–in words into the Acts. This case already shows the immense change
the Constitution brought forward.
The 5 techniques of interpretation by Du Plessis & Cordler (1994: 73–74) helped

Different Schools Of Statutory Interpretation

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