Legislative history and statutory interpretation

Abdula v. Canadian Solar Inc., 2012 ONCA 211 deals with the very limited use to which legislative history can be put in statutory interpretation:

[52]       It is important to note the extent to which legislative history may be considered in determining a law's purpose. The Supreme Court stated in Reference re: Firearms Act (Can.), 2000 SCC 31, [2000] 1 S.C.R. 783, at para. 17, that while a law's purpose is often stated in the legislation, it may also be determined by reference to extrinsic material such as the legislative history, as long as it is relevant, reliable and not assigned undue weight. This court discussed the use of committee reports as indicators of legislative meaning in Kerr v. Danier Leather Inc. (2005), 77 O.R. (3d) 321 (C.A.), at para. 119:

Traditionally, committee reports have been considered a relevant and admissible indicator of legislative purpose but not of legislative meaning...More recently, courts have begun to rely on these reports as evidence of legislative meaning. The weight to be accorded to any particular report must be assessed on a case-by-case basis[.]