Simon's Megalomaniacal Legal Resources

Statutes and Regulations - 'Headings' [Legislation Act, s.70]

. New Blue Ontario Fund v. Ontario (Chief Electoral Officer)

In New Blue Ontario Fund v. Ontario (Chief Electoral Officer) (Div Court, 2024) the Divisional Court illustrates some Election Finances Act procedures, here were a political party felt they were entitled to greater allowance subsidies.

Here, the court comments on the interpretive use of legislative 'headings':

[40] The Applicants submit that the word “schedule” in the heading to s. 32.1(2.1) means that this subsection was only meant to change the schedule for payments, not the entitlement to those payments. However, the Legislation Act, 2006, S.O. 2006, c. 21, Sch. F, s. 70 explicitly states that “headings are inserted in an Act or regulation for convenience of reference only and do not form part of it.” Thus, the words of the heading cannot be considered in interpreting s. 32.1(2.1).