Topic 5 · Approaches to Interpretation & Extrinsic Aids

LAW100 / LLM533 · Foundations of Law · UNE
Interactive Flow Guide
LDL Chapters 10 & 11
0 / 0 read
i — The interpretive shift

Statutory interpretation has shifted from text to context — but the text remains the starting point

Topic 5 covers the doctrinal core of how Australian courts read legislation. The premise is that legislation is the dominant source of new law (see Topic 4), and that reading it correctly is now the central modern legal skill. Chapters 10 and 11 of Laying Down the Law trace two intertwined questions: what approach does a court take to a provision's words (literal, golden, purposive, modern), and what materials may a court look at beyond the words themselves (the statute, the Act as a whole, extrinsic aids). The shift over the past four decades has been from the literalism of the early 20th century towards a contextual, purposive reading anchored by statutory mandate in s 15AA and s 15AB of the Acts Interpretation Act 1901[45] (Cth) and their state equivalents. Click any node for the doctrinal detail. Nodes marked Optional depth contain deeper analytical material that can be safely skipped on a first pass.

The fashion that defines the topic
"Law is a fashion industry. Over the last two or three decades the fashion in interpretation has changed from textualism to contextualism. Literal interpretation — a focus on the ordinary meaning of particular words — is no longer in vogue. Purposive interpretation is what we do now … In constitutional, statutory and contractual interpretation there does appear to have been a shift from text to context." — Spigelman CJ, From Text to Context: Contemporary Contractual Interpretation (Speech, Sydney, 21 March 2007)
The five eras at a glance
The doctrinal flow · how a court reads a provision today
↓ Step 1
↓ Step 2
↓ Step 3
↓ Step 4
↓ Step 5
↓ Outcome
The provocations running beneath this topic
ii — The historical foundation

The literal approach: words are read in their ordinary and natural sense — even when the result is inconvenient or improbable

The literal approach — known in the United States as the "plain meaning" rule — was the starting point for English and Australian statutory interpretation throughout the 19th century and most of the 20th. Its classical statement is by Higgins J in the Engineers' Case[1] in 1920: the language of the statute is to be obeyed in its ordinary and natural sense, "even if we think the result to be inconvenient or impolitic or improbable". The approach reflects a strong separation-of-powers concern: courts interpret, Parliament legislates, and the courts should not substitute their view of what the law ought to be for the words Parliament actually enacted. The literal approach has serious defects — it presumes words have a single fixed meaning, and it can yield absurd results. Higgon v O'Dea[2] is the textbook illustration of literalism producing an admittedly absurd conviction that the court nevertheless felt bound to uphold. The literal approach has been substantially modified by the modern approach and statutory mandate, but it has not been abandoned: the High Court has repeatedly affirmed that the task of construction "must begin with consideration of the text itself" (Alcan).

"The fundamental rule of interpretation, to which all others are subordinate, is that a statute is to be expounded according to the intent of the Parliament that made it; and that intention has to be found by an examination of the language used in the statute as a whole. The question is, what does the language mean; and when we find what the language means, in its ordinary and natural sense, it is our duty to obey that meaning, even if we think the result to be inconvenient or impolitic or improbable." — Higgins J, Amalgamated Society of Engineers v Adelaide Steamship Co Ltd[1] (1920) 28 CLR 129, 161–2
The doctrine · its origin, defect, and survival
↓ The defect
↓ Worked case
↓ The statute
↓ Method
↓ Decision
↓ Aftermath
The modern survival of literalism
iii — The first qualification

The golden rule: depart from ordinary meaning to avoid an absurdity, repugnance, or inconsistency — but no further

The golden rule, stated by Lord Wensleydale in Grey v Pearson[5] in 1857, is the first qualification on the literal approach. The grammatical and ordinary sense of words is to be adhered to, "unless that would lead to some absurdity, or some repugnance or inconsistency with the rest of the instrument, in which case the grammatical and ordinary sense of the words may be modified, so as to avoid that absurdity and inconsistency, but no farther". Two narrower readings of the rule and one broader reading have emerged. On the narrowest, the rule permits departure only to fix an internal inconsistency — that is, a problem with the language itself, such as a drafting error using "and" where "or" was intended. On the broader reading endorsed in Footscray City College v Ruzicka[8], the rule permits departure to avoid "patently unintended or absurd results" more generally. The line is delicate: in Higgon v O'Dea[2] the golden rule did not rescue the appellant, because the correction needed was too substantial (dropping an entire clause). The rule lives on in tension with — and increasingly absorbed into — the purposive approach.

"In construing wills and indeed statutes, and all written instruments, the grammatical and ordinary sense of the words is to be adhered to, unless that would lead to some absurdity, or some repugnance or inconsistency with the rest of the instrument, in which case the grammatical and ordinary sense of the words may be modified, so as to avoid that absurdity and inconsistency, but no farther." — Lord Wensleydale, Grey v Pearson[5] (1857) 6 HL Cas 61, 106; 10 ER 1216, 1234
The doctrine · origin, scope, and application
↓ Two readings
Worked examples · where the rule has applied
↓ Australian application
↓
↓ Limit
The rule's modern place
iv — The common-law purposive approach

The mischief rule: discern the mischief Parliament was addressing — and construe the Act to suppress it and advance the remedy

Long before statutory mandate, the common law had a purposive method. Its origin is Heydon's Case[9], decided in 1584, where all the judges of the Exchequer met and resolved that for the "sure and true interpretation of all statutes in general", four things must be discerned: the common law before the Act; the mischief and defect for which the common law did not provide; the remedy Parliament resolved to cure the disease; and the true reason of the remedy. The court's office is then to construe the statute "so as to suppress the mischief, and advance the remedy". The traditional common-law position was that the purposive approach applied only when the literal approach produced ambiguity or inconsistency — but that limit was always under pressure. Maritime Services Board of NSW v Posiden Navigation Inc[10] is the textbook illustration: the court used purpose to resolve a genuine ambiguity in favour of the broad reading consistent with the legislature's evident aim of holding polluters liable for the cost of clean-up. The common-law purposive approach has not been displaced by s 15AA — it co-exists with it, and remains particularly important when reading older legislation or interpreting in jurisdictions where the statutory provision uses the narrower "promote" formulation.

"[F]or the sure and true interpretation of all statutes in general (be they penal or beneficial, restrictive or enlarging of the common law), four things are to be discerned and considered: (1st) What was the common law before the making of the Act. (2nd) What was the mischief and defect for which the common law did not provide. (3rd) What remedy the Parliament hath resolved and appointed to cure the disease of the Commonwealth. And (4th) The true reason of the remedy." — Heydon's Case[9] (1584) 3 Co Rep 7a, 7b; 76 ER 637, 638
The four questions of Heydon's Case
1
Common law before the Act
What was the position before Parliament intervened? Identify the legal landscape the Act entered.
2
Mischief & defect
What inadequacy or harm did the common law fail to address? What needed fixing?
3
Remedy
What remedy did Parliament appoint "to cure the disease of the Commonwealth"?
4
Reason of the remedy
What was the underlying rationale? Construe to suppress mischief, advance remedy.
§
The maxims
pro privato commodo (for private gain) vs pro bono publico (for public benefit)
The traditional limit · and its erosion
↓ Pressure
Worked case · Maritime Services Board v Posiden
↓ The choice
↓ Decision
Where purposive can fail
v — The statutory purposive turn

Since 1981, every Australian jurisdiction has mandated purposive interpretation by statute — but the wording, and the practical effect, differ

In 1981 the Commonwealth Attorney-General's Department convened a symposium on improving statutory interpretation, prompted by public criticism of literalist High Court tax decisions. Later that year, Parliament enacted s 15AA of the Acts Interpretation Act 1901[45]. The original version required that a construction promoting purpose be "preferred to a construction that would not promote that purpose". The 2011 amendment strengthened it: the interpretation that "best achieves" the purpose is to be preferred to each other interpretation. The states and territories followed Commonwealth's lead but did not all adopt the stronger formulation. Australia now operates on two camps: "best achieves" (Cth, ACT, Qld, SA) and "promote" (NSW, NT, Tas, Vic, WA). The High Court in Mills v Meeking[15] confirmed three crucial features: s 15AA operates whether or not there is patent ambiguity; it permits a court to consider purpose in determining whether more than one construction is open; and it does not licence a re-writing of the Act. Gleeson CJ in Carr v Western Australia[18] added a vital limitation: where legislation balances competing interests, naming "the" purpose can mislead. Where there is no obvious purpose, the courts must not construct one — that would be judicial legislation.

The statutory provision · before and after 2011
Original s 15AA (1981–2011) · "preferred"
Current s 15AA (2011–) · "best achieves"
The two camps · "best achieves" vs "promote"
Jurisdiction
Provision Wording standard
Notes Particularities
Cth
s 15AA Acts Interpretation Act 1901
"Best achieves" (since 2011)
ACT
s 139 Legislation Act 2001
"Best achieves"
Qld
s 14A Acts Interpretation Act 1954
"Best achieves"
SA
s 14 Legislation Interpretation Act 2021
"Best achieves" (since 2021)
NSW
s 33 Interpretation Act 1987
"Promote"
NT
s 62A Interpretation Act 1978
"Promote"
Tas
s 8A Acts Interpretation Act 1931
"Promote"
Vic
s 35(a) Interpretation of Legislation Act 1984
"Promote"
WA
s 18 Interpretation Act 1984
"Promote"

All provisions apply to delegated legislation made under the relevant Acts.

How s 15AA operates · key principles
↓ Limit
The major limitation · Carr v Western Australia
↓
The reassurance
vi — Context and the modern approach

The modern approach: context must be considered in the first instance — and may extend to the prior state of the law and the mischief

The "modern approach" is the dominant interpretive paradigm in Australia, drawing together the literal anchor, the purposive mandate of s 15AA, and a wide conception of "context". Its locus classicus is the joint judgment in CIC Insurance Ltd v Bankstown Football Club Ltd[23], where Brennan CJ, Dawson, Toohey and Gummow JJ said the modern approach "insists that the context be considered in the first instance, not merely at some later stage when ambiguity might be thought to arise" and uses context "in its widest sense" to include the existing state of the law and the mischief the statute was intended to remedy. Context, as Mason J had earlier observed, has three operative meanings: the narrow syntactical context of the words; the context of the Act as a whole; and the widest context including legislative history and the prior state of the law. The modern approach has a controversial corollary — that where a drafting error has prevented Parliament's evident purpose from being achieved, a court may "read in" words that Parliament would have used had its attention been drawn to the defect. That doctrine ran on parallel lines (Bermingham[21], Leys[26], R v Young[25]) until the High Court's 3:2 decision in Taylor v Owners — Strata Plan No 11564[27] in 2014 attempted to settle the position. The result: purposive construction may support reading in additional words to fix simple grammatical errors, but not to fill substantive "gaps" or make insertions that depart materially from the language Parliament used. The reversion-to-text question (Alcan[4], Saeed[43]) is canvassed under Panel vii.

"To read the section in isolation from the enactment of which it forms a part is to offend against the cardinal rule of statutory interpretation that requires the words of a statute to be read in their context … The modern approach to interpretation insists that the context be considered in the first instance, especially in the case of general words, and not merely at some later stage when ambiguity might be thought to arise." — Mason J, K & S Lake City Freighters Pty Ltd v Gordon & Gotch Ltd[20] (1985) 157 CLR 309, 315
The three meanings of "context"
Scope
What it covers Substantive content
Where in this guide Cross-reference
Narrow
Syntactical context
Words in surrounding text
OperationThe immediate textual environment of a word or phrase — the sentence, the section, the punctuation, the conjunctions. Reading words in isolation breaches "the cardinal rule" (Mason J).
Coming in Topic 6Syntactical maxims like noscitur a sociis, ejusdem generis, and expressio unius est exclusio alterius operate at this narrow level. LDL Ch 12.
Middle
Act as a whole
Internal structure of the statute
OperationThe provision read in light of the long title, preamble, purpose clause, other sections, headings, schedules, and definitions. A consistent meaning across the Act is presumed.
Already in Higgins JEven the classical literal approach in Engineers' Case[1] required examination of "the language used in the statute as a whole" — Act-wide context was never controversial.
Widest
External context
Prior law, mischief, extrinsic materials
OperationThe existing state of the law before the Act; the mischief the Act addresses; the legislative history; the facts and circumstances within the knowledge or contemplation of the legislature.
CIC Insurance principlePer CIC Insurance[23], this widest context is considered in the first instance. No threshold test for using extrinsic materials at common law. See Panel vii.
The locus classicus · CIC Insurance → Project Blue Sky
↓ One year later · consolidated into the unit's source case
↓ Recent application
Reading in words · the Taylor jurisprudence
↓ The competing approaches
↓ Vic refinement
↓ HCA resolution · 2014
↓ Test
vii — Extrinsic aids to interpretation

Extrinsic materials are now routinely consulted — but only the common-law modern approach permits their use without a threshold

Extrinsic materials are documentary materials outside the statute being interpreted: second-reading speeches, explanatory memoranda, reports of Royal Commissions and Law Reform Commissions, parliamentary debates (Hansard), international agreements. The traditional common-law position, affirmed by the High Court as recently as 1977 in Commissioner for Prices and Consumer Affairs v Charles Moore[29], was that parliamentary debates were not admissible for any purpose. That orthodoxy began to crack in Wacando[30] (1981) and Whitfords Beach[31] (1982), where Mason J suggested an exception where a Bill addressed a mischief. The Commonwealth held a second symposium in 1983 and enacted s 15AB of the Acts Interpretation Act 1901[45] in 1984, followed by equivalents in every state and territory. Section 15AB permits — but does not require — recourse to extrinsic materials in two situations: to confirm the ordinary meaning, or to determine meaning where the threshold test is met (ambiguity, obscurity, or manifest absurdity). The Australian Capital Territory and Victorian provisions are not subject to that threshold. Separately, the common-law modern approach affirmed in CIC Insurance[23] permits resort to extrinsic materials as part of "context in its widest sense" without any threshold. Some recent obiter (Alcan[4], Saeed[43]) suggested a "reversion to text", but Cunneen[40], R v A2[41] and R v Rolfe[42] confirm the modern approach remains good law. The constant warning, from Re Bolton; Ex parte Beane[34] through to Melco Resorts[44]: "The words of a Minister must not be substituted for the text of the law."

The historical arc · from exclusion to embrace
i
1977 · Traditional bar
Charles Moore — parliamentary debates not admissible for any purpose as an aid to construction.
ii
1981–82 · Mason J's exception
Wacando & Whitfords Beach — when a Bill remedies a mischief, debates may be consulted.
iii
1984 · s 15AB enacted
After 1983 symposium, statutory permission introduced — with threshold conditions.
iv
1997 · CIC Insurance
Common-law modern approach — no threshold; context in first instance.
v
2015–21 · Settled
Cunneen, R v A2, R v Rolfe confirm modern approach; reversion-to-text obiter not followed.
What counts as "extrinsic material"
Parliamentary materials
External materials
Section 15AB · the statutory regime
State and territory equivalents · structural map
Jurisdiction
Provision Wording standard
Threshold test? Limb (b) restriction
Cth
s 15AB Acts Interpretation Act 1901
Yes — threshold required
NSW
s 34 Interpretation Act 1987
Yes — based on s 15AB
NT
s 62B Interpretation Act 1978
Yes — based on s 15AB
Qld
s 14B Acts Interpretation Act 1954
Yes — special definition of "extrinsic material" applies under Statutory Instruments Act 1992[51] (Qld) s 15
SA
s 16 Legislation Interpretation Act 2021
Yes — based on s 15AB
Tas
s 8B Acts Interpretation Act 1931
Yes — based on s 15AB
WA
s 19 Interpretation Act 1984
Yes — based on s 15AB
ACT
ss 141–143 Legislation Act 2001
No threshold — material "may be considered" without limit
Vic
s 35(b) Interpretation of Legislation Act 1984
No threshold — extends purposive mandate of s 35(a)
Operation · how the threshold test bites
↓
↓ Warning
Worked case · Re Shingles
↓ Threshold
↓ Extrinsic material
The reversion-to-text question
International agreements · a special case
viii — Method and Exercise 13

A working method for interpreting a provision — and the five problems from Laying Down the Law Exercise 13

The doctrinal panels (ii to vii) explain what the courts have decided. This panel is operational: a stepwise method for working through any interpretive problem, followed by Exercise 13 from LDL (12th ed) page 388 — the sample problem with a worked answer, and the five problems with hints. The exercise can be answered using any of the approaches you have studied, but the modern approach (Panel vi) is the orthodox starting point. Use the method as a scaffold; do not be mechanical. Different problems will need different combinations of approach and authority. As Dr Day frames it: think of the approaches as tools in a toolkit (or ingredients in a recipe, or items in a makeup case) — bring out the right one for the job.

A working method · adapt to the problem
1
In force?
Check the provision is in force at the relevant date. Use the point-in-time view.
2
Map the Act
Read table of contents and headings. Locate the provision in the Act's structure.
3
Break to elements
Lay out the provision element by element. Mark the conjunctions: AND vs OR.
4
Ordinary meaning
Identify the literal meaning. Check the Act's definitions and the Interpretation Act.
5
Context — Act
Read in the context of the Act as a whole. Adjacent provisions, long title, purpose clause.
6
Purpose
Identify the Act's purpose. Apply s 15AA or equivalent. Best achieves vs promote.
7
Extrinsic?
If ambiguity or absurd result, consult extrinsic materials per s 15AB or CIC Insurance.
Sample problem · with full worked answer
The five problems
The closing reminder
ix — Reference

The cases, statutes, key terms, and further reading that anchor Topic 5

A consolidated AGLC4-compliant reference list for Topic 5. Each entry has a stable number; superscript markers in the body and modal text link to the relevant entry, which is highlighted on arrival. A small "Back" button appears at the bottom right that returns you to where you were. Cases are numbered 1–44; statutes 45–65.

Cases

Literal approach

[1]
Amalgamated Society of Engineers v Adelaide Steamship Co Ltd (1920) 28 CLR 129
[2]
Higgon v O’Dea [1962] WAR 140
[3]
Secretary, Department of Health v Harvey (1990) 21 ALD 393
[4]
Alcan (NT) Alumina Pty Ltd v Commissioner of Territory Revenue (2009) 239 CLR 27

Golden rule

[5]
Grey v Pearson (1857) 6 HL Cas 61; 10 ER 1216
[6]
Adler v George [1964] 2 QB 7
[7]
King v Rowlings [1987] VR 20
[8]
Footscray City College v Ruzicka (2007) 16 VR 498

Purposive (common law)

[9]
Heydon’s Case (1584) 3 Co Rep 7a; 76 ER 637
[10]
Maritime Services Board of NSW v Posiden Navigation Inc [1982] 1 NSWLR 72
[11]
Avel Pty Ltd v Attorney-General (NSW) (1987) 11 NSWLR 126
[12]
Pambula District Hospital v Herriman (1988) 14 NSWLR 387

Purposive (statutory) and limits

[13]
Cooper Brookes (Wollongong) Pty Ltd v Federal Commissioner of Taxation (1981) 147 CLR 297
[14]
Chugg v Pacific Dunlop Ltd (1990) 170 CLR 249
[15]
Mills v Meeking (1990) 169 CLR 214
[16]
R v L (1994) 49 FCR 534
[17]
Whittaker v Comcare (1998) 86 FCR 532
[18]
Carr v Western Australia (2007) 232 CLR 138
[19]
Australian Education Union v Department of Education and Children’s Services (2012) 248 CLR 1

Modern approach (Common law)

[20]
K & S Lake City Freighters Pty Ltd v Gordon & Gotch Ltd (1985) 157 CLR 309
[21]
Bermingham v Corrective Services Commission (NSW) (1988) 15 NSWLR 292
[22]
Tokyo Mart Pty Ltd v Campbell (1988) 15 NSWLR 275
[23]
CIC Insurance Ltd v Bankstown Football Club Ltd (1997) 187 CLR 384
text, context, purpose
[24]
Project Blue Sky Inc v Australian Broadcasting Authority (1998) 194 CLR 355
Reading in words
[25]
R v Young (1999) 46 NSWLR 681
[26]
DPP (Vic) v Leys (2012) 44 VR 1
[27]
Taylor v Owners — Strata Plan No 11564 (2014) 253 CLR 531
[28]
Lowe v The Queen (2015) 48 VR 351
Later applications
[43]
Saeed v Minister for Immigration and Citizenship (2010) 241 CLR 252
[44]
Attorney-General (NSW) v Melco Resorts & Entertainment Ltd (2020) 102 NSWLR 256

Extrinsic aids

[29]
Commissioner for Prices and Consumer Affairs (SA) v Charles Moore (Aust) Pty Ltd (1977) 139 CLR 449
[30]
Wacando v Commonwealth (1981) 148 CLR 1
[31]
Commissioner of Taxation (Cth) v Whitfords Beach Pty Ltd (1982) 150 CLR 355
[32]
Re Shingles and Director-General of Social Security (1984) 6 ALD 568
[33]
Re Australian Federation of Construction Contractors; Ex parte Billing (1986) 68 ALR 416
[34]
Re Bolton; Ex parte Beane (1987) 162 CLR 514
[35]
Saraswati v The Queen (1991) 172 CLR 1
[36]
Applicant A v Minister for Immigration and Ethnic Affairs (1997) 190 CLR 225
[37]
Newcastle City Council v GIO General Ltd (1997) 191 CLR 85
[38]
Povey v Qantas Airways Ltd (2005) 223 CLR 189
[39]
Certain Lloyd’s Underwriters v Cross (2012) 248 CLR 378
[40]
Independent Commission Against Corruption (NSW) v Cunneen (2015) 256 CLR 1
[41]
R v A2; R v Magennis; R v Vaziri (2019) 269 CLR 507
[42]
R v Rolfe (2021) 273 CLR 413

Statutes

Commonwealth

[45]
Acts Interpretation Act 1901 (Cth)
[46]
Legislation Act 2003 (Cth)
[47]
Migration Act 1958 (Cth)

New South Wales · Victoria · Queensland

[48]
Interpretation Act 1987 (NSW)
[49]
Interpretation of Legislation Act 1984 (Vic)
[50]
Acts Interpretation Act 1954 (Qld)
[51]
Statutory Instruments Act 1992 (Qld)

Western Australia · South Australia · Tasmania

[52]
Interpretation Act 1984 (WA)
[53]
Legislation Interpretation Act 2021 (SA)
[54]
Acts Interpretation Act 1931 (Tas)

Australian Capital Territory · Northern Territory

[55]
Legislation Act 2001 (ACT)
[56]
Human Rights Act 2004 (ACT)
[59]
Interpretation Act 1978 (NT)

Other rights-compatible interpretation provisions

[58]
Charter of Human Rights and Responsibilities Act 2006 (Vic)
[57]
Human Rights Act 2019 (Qld)

Worked-case statutes

[60]
Police Act 1892 (WA)
[61]
Police Act 1963 (WA)
[62]
Prevention of Oil Pollution of Navigable Waters Act 1960 (NSW)
[63]
Social Security Act 1947 (Cth)
[64]
Official Secrets Act 1920 (UK)

International instrument

[65]
Vienna Convention on the Law of Treaties

Key terms

Approaches

Literal approach — words read in their ordinary and natural sense (US: plain-meaning rule).

Golden rule — depart from ordinary meaning to avoid absurdity, repugnance, or inconsistency.

Mischief rule — discern the mischief Parliament addressed and the remedy appointed; construe to suppress the mischief and advance the remedy.

Purposive approach — construe to give effect to Parliament’s purpose; mandated by s 15AA and equivalents.

Modern approach — context (including widest context) considered in the first instance; per CIC Insurance.

Materials

Extrinsic materials — materials outside the text of the Act capable of throwing light on its purpose or meaning.

Second-reading speech — speech by the Minister moving that a Bill be read a second time; the most frequently cited extrinsic material.

Explanatory memorandum — document tabled by a Minister explaining the Bill clause by clause.

Threshold test — under s 15AB(1)(b), the ambiguity-or-absurdity requirement for using extrinsic materials to determine meaning.

Latin maxims

pro privato commodo — for private gain (Heydon’s Case).

pro bono publico — for the public benefit (Heydon’s Case).

Constitutional anchors

Separation of powers — the rationale for textualism and the constraint on purposive interpretation. Courts interpret; Parliament legislates.

"Construction is not repair" — Gageler & Keane JJ in Taylor: the limit on reading in words.

Dualism — Australia’s treatment of treaties: they do not become domestic law without enactment.

Further reading

Comprehensive texts

Dennis C Pearce, Statutory Interpretation in Australia (LexisNexis Butterworths, 9th ed, 2019)

Dennis C Pearce, Interpretation Acts in Australia (LexisNexis, 2nd ed, 2023)

Kath Hall and Claire Macken, Statutory Interpretation: Principles and Context (LexisNexis, 2021)

Michelle Sanson, Statutory Interpretation (Oxford University Press, 2nd ed, 2017)

Edited collections & articles

Suzanne Corcoran and Stephen Bottomley (eds), Interpreting Statutes (Federation Press, 2005)

Rick Bigwood (ed), The Statute: Making and Meaning (LexisNexis Butterworths, 2004)

Lisa Burton Crawford and Dan Meagher, 'Statutory Precedents under the "Modern Approach" to Statutory Interpretation' (2020) 42 Sydney Law Review 209

James J Spigelman, 'The Poet’s Rich Resource: Issues in Statutory Interpretation' (2001) 21 Australian Bar Review 224

Robert S Geddes, 'Purpose and Context in Statutory Interpretation' (2005) 2 University of New England Law Journal 5