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References in statutes passed after 1st January, 1890, are to the revised edition, if any; otherwise, if passed before George I., to the edition prepared under the direction of the Record Commission, in other cases to the Queen's Printer's or Stationery Office Copy.

Lord Brougham's Act, 1850 (13 & 14 Vict. c. 21), commenced and took effect from and immediately after the 4th of February, 1851 (repealed, 52 & 53 Vict. c. 63, s. 41).

Sect. 3.-"Be it enacted, that in any Act, when any former Act is referred to, it shall be sufficient, if such Act was made before the seventh year of Henry the Seventh [22nd August, 1492],

"To cite the year of the King's reign in which it was made, and where there are more statutes than one in the same year the statute, and where there are more chapters than one the chapter: "And if such Act referred to was made after the fourth year of Henry the Seventh [22nd August, 1489],

"To cite the year of the reign, and where there are more statutes or sessions than one in the same year the statute or session (as the case may require), and where there are more chapters or sections than one the chapter or section or chapter and section (as the case may require),

"Without reciting the title of such Act, or the provision of such section, so referred to;

"And the reference in all cases shall be made according to the copies of statutes printed by the Queen's Printer, or to the copies thereof contained in the reports of the Commissioners of Public Records:

"Provided that where it is only intended to amend or repeal any portion only of such section it shall be necessary still either to recite such portion or to set forth the matter or thing intended to be amended or repealed."

Interpretation Act, 1×89 (52 & 53 Vict. c. 63) [30th August, 1889].

Sect. 35.-(1.) "In any Act, instrument, or document, an Act may be cited by reference to the short title, if any, of the Act, either with or without a reference to the chapter, or by reference to the regnal year in which the Act was passed, and where there are more statutes or sessions than one in the same regnal year, by reference to the statute or the session, as the case may require, and where there are more chapters than one, by reference to the chapter,

and any enactment may be cited by reference to the section or subsection of the Act in which the enactment is contained.

(2.) "Where any Act passed after the commencement of this Act [1st January, 1890] contains such reference as aforesaid, the reference shall, unless a contrary intention appears, be read as referring, in the case of statutes included in any revised edition of the statutes purporting to be printed by authority, to that edition, and in the case of statutes not so included, and passed before the reign of King George the First, to the edition prepared under the direction of the Record Commission; and in other cases to the copies of the statutes purporting to be printed by the Queen's Printer, or under the superintendence or authority of Her Majesty's Stationery Office.

(3.) "In any Act passed after the commencement of this Act [1st January, 190], a description or citation of a portion of another Act shall, unless the contrary intention appears, be construed as including the word, section, or other part mentioned or referred to as forming the beginning and as forming the end of the portion comprised in the description or citation."

Short Titles Act, 1892 (55 Vict. c. 10) [20th May, 1892] (repealed by Short Titles Act, 1896 (59 & 60 Vict. c. 14), s. 4).

Sect. 1.-(1.) "Each of the Acts mentioned in the First Schedule to this Act may, without prejudice to any other mode of citation, be cited by the short title therein mentioned in that behalf.

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(2.) Each of the groups of Acts mentioned in the Second Schedule to this Act may, without prejudice to any other mode of citation, be cited by the collective title therein mentioned in that behalf.

(3.) "If "If any Act passed after this Act is directed, as to the whole or any part thereof, to be read with any of the groups of Acts mentioned in the Second Schedule to this Act, that group shall be construed as including that Act or part, and, if the collective title of the group states the first and last years of the group, the year in which that Act is passed shall be substituted for the last year of the group, and so on as often as a subsequent Act or part is added to the group.

Sect. 2. " This Act may be cited as the Short Titles Act, 1892."

Short Titles Act, 1896 (59 & 60 Vict. c. 14) [20th July, 1896].

Citation by Short Title.

Sect. 1. Each of the Acts mentioned in the First Schedule to this Act may, without prejudice to any other mode of citation, be cited by the short title therein mentioned in that behalf.

Citation by Collective Title.

2. (1) Each of the groups of Acts mentioned in the Second Schedule to this Act may, without prejudice to any other mode of citation, be cited by the collective title therein mentioned in that behalf.

(2) If it is provided that any Act passed after this Act may, as to the whole or any part thereof, be cited with any of the groups of Acts mentioned in the Second Schedule to this Act, or with any group of Acts to which a collective title has been given. by any Act passed before this Act, that group shall be construed as including that Act or part, and if the collective title of the group states the first and last years of the group, the year in which that Act is passed shall be substituted for the last year of the group, and so on as often as a subsequent Act or part is added to the group.

Effect of Repeal of Enactment giving a Short Title.

3. Notwithstanding the repeal of an enactment giving a short title to an Act the Act may, without prejudice to any other mode of citation, continue to be cited by that short title.

4. The Short Title Act, 1892, is hereby repealed.

5. This Act may be cited as the Short Titles Act, 1896.

Title of a Statute.

The title of a statute was not prior to 1854, but is now, a part of the statute.

The title of a statute may be looked at in order to remove ambiguity in the words of the statute, and to ascertain its scope and object.

"The title of an Act of Parliament is no part of the law or enacting part, no more than the title of a book is part of the book ;

for the title is not the law, but the name or description given to it by the makers."-Mills v. Wilkins (1704), 6 Mod. 62, Holt, C. J.

"The conciseness of the title shall not control the body of the Act. The title is no part of the law itself. One reading is often sufficient for it."--The King v. Williams (1758), 1 W. Bl. 93, at p. 95, Mansfield, C. J., et tot. cur.

"The title of the Act has also been mentioned; but although it has occasionally been referred to as aiding in the construction of an Act, particularly by Sir John Nicoll in Brett v. Brett [(1826), 3 Addams, 210, at p. 216], it is certainly no part of the law, and, in strictness, ought not to be taken into consideration at all: Lord Coke, Poulter's case (1611), Coke, Part XI. 33; Lord Holt, Mills v. Wilkins (1704), 6 Mod. 62; Lord Mansfield, Rex v. Williams (1758), I Wm. Bl. 93; and Lord Hardwicke, The Att.-Gen. v. Weymouth (1743), Ambler, 22."-Salkeld v. Johnson (1848), 2 Ex. 256, at pp. 282, 283; 18 L. J. Ex. 89, at p. 97, Pollock, C. B.

"The title cannot be resorted to in construing the enactments." -Hunter v. Nockolds (1850), 1 Mac. & G. 640, at p. 651; 19 L. J. Ch. 177, at p. 178, Lord Cottenham, L. C.

"The title of an Act of Parliament is no part of the law, but it may tend to show the object of the legislature."”—-Johnson v. Upham (1859), 2 E. & E. 250, at p. 263; 28 L. J. Q. B. 252, at p. 257, Wightman, J.

"The title of the Act is always on the roll."-Sutton v. Sutton (1882), 22 Ch. D. 511, at p. 513, Jessel, M. R.

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"In Maxwell on the Interpretation of Statutes, the author (at p. 34) states that the title of an Act of Parliament is not regarded by the Court as forming part of the Act. In Sedgwick's Interpretation of Statutory and Constitutional Law, at p. 50, it is said that the title may be resorted to in order to remove ambiguities. In Chance v. Adams [(1697), 1 Ld. Raym. 77], Treby, C. J., said that the title of the Act was but a new usage, and began about the 11th of Hen. VII.' In Mills v. Wilkins [(1704), 6 Mod. 62], Holt, C. J., thought that the title was no part of the law or enacting part of the statute. But there is considerable authority in favour of reading the title to get at the object of the Act. In Stradling v. Morgan [(1560), Plow. 199], the title of the Act was relied on in deciding whether the word 'receivers' in 7 Edw. VI. c. 1, applied to receivers generally, or was confined to the king's receivers only. So in The King v. Cartwright [(1791), 4 T. R. 490], Buller, J., in deciding that assaults upon revenue officers, which

could be prosecuted in any Court under sect. 26 of 9 Geo. II. c. 35, only extended to assaults upon them quâ government officers, said that the intention of the legislature might be gathered from other parts of the Act, which was made for the sake of the revenue, as its title imported.' In The King v. Marks [(1802), 3 East, 157], the Court looked at the title to determine the scope of the Act under consideration. I think, therefore, there is ample authority for saying that the title of an Act may be looked at in order to remove any ambiguity in the words of the Act."-Coomber v. Justices of Berks (1882), 9 Q. B. D. 17, at pp. 32, 33; 51 L. J. Q. B. 297, at p. 304, Huddleston, B.

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"The title of the Act, which may be referred to for the purpose of ascertaining generally the scope of the Act, is "-East and West India Dock Co. v. Shaw, Savill and Albion Co. (1888), 39 Ch. D. 524, at p. 531; 57 L. J. Ch. 1038, at p. 1040, Chitty, J. (cited by Lord Macnaghten in Fenton v. Thorley & Co., Ltd., [1903] A. C. 443, at p. 447; 72 L. J. K. B. 787, at p. 789).

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"The title of a statute does not go for much in construing it; but I do not know that it is absolutely to be disregarded.' Kenrick v. Lawrence (1890), 25 Q. B. D. 99, at p. 104, Wills, J. "The title, it is true, is no part of the Act, but, as was said by Jessel, M. R., in Sutton v. Sutton [(1882), 22 Ch. D. 511, at p. 513], it is always on the roll, and may be looked at in order to remove any ambiguity in the words of the Act. It cannot be used to control the express provisions of an Act; yet, if there be in these provisions anything admitting of a doubt, the title of the Act is a matter proper to be considered in order to assist in the interpretation of the Act, and thereby to give to the doubtful language in the body of the Act a meaning consistent, rather than at variance, with the clear title of the Act." -Powell v. Kempton Park Racecourse Co., [1897] 2 Q. B. 242, at p. 265; 66 L. J. Q. B. 601, at pp. 613, 614, Lopes, L. J.

"The title may be dealt with shortly. With reference to Acts passed as this was before 1854, when the practice of the House of Commons was altered by Standing Order 34, which for the first time authorized the House in Committee to amend the title, there is a great preponderance of authority in favour of the proposition that the title forms no part of the Act, and cannot even be looked at for the purpose of construing the Act. (See Maxwell on Statutes, 2nd ed., pp. 50, 51, and cases there cited.)"-Ibid., at p. 289; L. J., at p. 626, Rigby, L. J.

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