Modern statutory interpretation

Matthews v. Algoma Timberlakes Corporation, 2010 ONCA 468 is a good source for the modern rule regarding statutory interpretation as well as a source for using legislative debates in interpreting statues.

The Court holds:

[22] The modern rule of statutory interpretation requires that “the words of an Act ... be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: Bell ExpressVu Limited Partnership v. Rex, [2002] 2 S.C.R. 559, at para. 26, citing Elmer A. Driedger, Construction of Statutes, 2d ed. (Toronto: Butterworths, 1983), at p. 87. Given the remedial nature of the Act, its provisions must be interpreted liberally to ensure the realization of its objectives. See Canada (Human Rights Commission) v. Canadian Airlines International Ltd., [2006] 1 S.C.R. 3, at para. 16.

[23] In this case, s. 1 of the Act provides that one of the legislation’s primary purposes is to protect residential tenants from unlawful rent increases and evictions. The Honourable R. Roy McMurtry, the Attorney General at the time, explained that the purpose behind extending the application of these protections to mobile homes (and later to land lease sites) was to provide tenants of those premises with security of tenure and other protections that had been available to other tenants.[3] To ensure that protection, the legislation provided a broad definition of a “rental unit”.