Statutory Interpretation Practice Assessment 2 Solution, LAW5111, USQ

This document presents a comprehensive solution to a statutory interpretation assignment, focusing on the analysis of the Manufacture of Prohibited Drugs Act 2015 (Cth) and the Commonwealth of Australia Members of Parliament Integrity and Correctness Act of 2017 (Cth). The solution addresses co...Read More

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Statutory Interpretation

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Table of Contents
Answer 1....................................................................................................................................3
Constitutional validity of the Act...........................................................................................3
Jurisdiction and Commencement of the Act..........................................................................3
Classification of the Act.........................................................................................................3
Operative provisions..............................................................................................................3
Purpose of the Act..................................................................................................................4
Intrinsic materials...............................................................................................................4
Extrinsic materials..............................................................................................................6
Context...................................................................................................................................7
Broader context..................................................................................................................7
Advice to Amelia...............................................................................................................7
Answer 2....................................................................................................................................8
Answer 3....................................................................................................................................9
Constitutional validity............................................................................................................9
Jurisdiction and commencement............................................................................................9
Advice to Amelia...................................................................................................................9
Section 8 B.........................................................................................................................9
Section 8 C.......................................................................................................................10
Answer 4..................................................................................................................................11
Reference List..........................................................................................................................12

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Answer 1
Constitutional validity of the Act
The Act is purported to govern the activities and functions along with the regulations
concerning the members of the Parliament of Australia. Hence it is valid as per the
Constitution of Australia as far as the establishment of trust amongst the members is
concerned in addition to the making of claims for the expenses accordingly with regard to the
influence upon the processes related to the making of decisions accordingly.
The Act is a legislation of the Commonwealth. Therefore, the Acts Interpretation Act of 1901
(Cth) would be applicable accordingly.
Jurisdiction and Commencement of the Act
When the offence was committed, the Commonwealth of Australia Members of Parliament
Integrity and Correctness Act of 2017 (Cth) was in force since it is understood from the facts
and circumstances of the provided scenario that the offence took place on 18th August, 2017
and the Act of 2017 received Royal Assent on 3rd July, 2017. Section 2 of the Act of 2017
implies that the Act of 2017 would come into force and be applicable once it receives Royal
Assent accordingly. As a result, it is imperative that the Act of 2017 has jurisdiction in terms
of addressing the issues in an efficient manner as far as the Parliament of Australia is
concerned. The Act of 2017 is Commonwealth legislation as the scenario revolves around the
Parliament House at Canberra.
Classification of the Act
The Act of 2017 is a penal statute as it contains provisions relating to penalties such as fines
in addition to the terms of imprisonment accordingly. In the case of R v Beckwith, it was held
by the High Court of Australia that the penal acts are to be construed narrowly as far as the
understanding of their meaning in a lucid manner is concerned with reference to the
comprehensive results, unless there are express terms incorporated in the Act. As a result, the
plain meaning rule of interpretation would be helpful in the application of the Act of 2017 as
far as the effective outcomes are concerned with regard to the resolution of the issues in an
incredible manner accordingly.
Operative provisions
Sub-section 1 of Section 4 of the Act of 2017 implies the prohibition in terms of personal
relationships between a member of the Parliament and a Minister thereby leading to the
violation of the Act of 2017 accordingly. In this regard, personal relationships would mean
any kind of intimate, physical or sexual relationship that is beyond the working hours of the
Parliament of Australia as per the understanding of Section 3 of the Act of 2017 . The
concept of engagement as meant by Section 3 of the Act of 2017 would also be applicable
taking account of the facts and circumstances of the case in a detailed manner. Section 7 of
the Act of 2017 implies that the making of expense claims in an unlawful manner would
constitute an offence accordingly. As a result, it can be deduced that such provisions would
help in the identification of the offences and the imposition of the penalties accordingly that

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would help in the resolution of the issues in a proper manner as far as the desired results are
concerned.
Purpose of the Act
As understood by Section 15 AA of Acts Interpretation Act of 1901 (Cth), the purpose of the
interpretation of a statute should result in the achievement of the best interests of the statute
as far as the comprehensive results are concerned in the interests of fairness and equality
taking account of the principles of natural justice. It is imperative that the ordinary meaning
of the words need to be taken into consideration in terms of the interpretation of a statute as
far as the literal rule of statutory interpretation is concerned (Smith, 2016). As a result, it is
observed that the Act of 2017 needs to be interpreted in manner which would lead to the best
results as far as the facts and circumstances of the given scenario are concerned accordingly
that would lead to the addressing of the issues in an efficient manner with reference to natural
justice. Therefore, it is inferred that the simple meaning of the words in a statute need to be
taken into account in order to ensure that the interpretation of the statue is effective in order
to meet the objectives as far as the best interests are concerned taking account of the scenario
in question which would ultimately lead to beneficial outcomes in the long run with reference
to the purpose and context of the statute accordingly.
Intrinsic materials
The intrinsic materials in this regard are the ones that are included in the Act of 2017. The
elements that constitute the intrinsic materials include, short title, notes, headings of sections
along with schedules and punctuation accordingly that would help in the understanding of the
main objectives of the statute by the virtue of the application of the plain meaning rule of
interpretation as far as the desired results are concerned. In this regard, Section 1 of the Act
of 2017 needs to be taken into consideration and analysed in an in-depth manner so as to get a
clear understanding of the Act of 2017 as far as the effective results are concerned. If it is
observed that there is no excusive mention of the purpose of the Act, the court will be under
an obligation to delve into the purpose and come to a conclusion with reference to the merits
of the case as held by the Federal Court of Australia in the case of Municipal Officers’
Association of Australia v Lancaster.
As implied by Sub-section 3 of Section 1 of the Act of 2017, the promotion of trust amongst
the ministers is one of the key objectives of the Act of 2017 that would ensure the conduct of
the ministers in a proper manner as far as the desired outcomes are concerned accordingly. It
is also observed that the main objective of the Act of 2017 is to imply the promotion of trust
of the public in terms of the activities of the Ministers accordingly (Staszewski, 2015). The
activities in this regard include personal relationships, personal assets that play the role in the
processes involved in the making of the decisions and the claims being made with regard to
expenses accordingly. The objectives are enshrined in various provisions of the Act of 2017
as far as the explanation in a clear and lucid manner is concerned that would facilitate the
ease of understanding in an efficient manner in terms of the beneficial outcomes in the long
run.

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Section 4 of the Act of 2017 implies the prohibition of personal relationships in the office as
understood by Sub-section 1. There are certain aspects as per Sub-section 2 that implies
personal relationships. Sub-section 3 implies that the onus of proof lies on the Minister with
regard to the actions being lawful. The penalty for such kind of an offence would be the
removal of the minister from the office on an immediate basis as far as the aspect of
stringency is concerned with regard to the maintenance of morality and ethics.
Section 7 of the Act of 2017 implies that the claiming of expenses in an unlawful manner
which would contravene Schedule 1 of the Act of 2017 constitutes an offence. It also extends
to the making of unlawful claims in terms of any allowance concerned accordingly. The
penalty in this regard would be twenty thousand dollars or imprisonment for a term of two
years taking account of the facts and circumstances of the scenario in a detailed manner.
Section 8 of the Act of 2017 implies that a Register of Interests needs to be maintained and
updated in an efficient manner as far as the keeping of the records in a proper manner is
concerned (Aust and Nolte, 2016). In this regard, Section 5 of the Act of 2017 the interests
need to be declared in an appropriate manner failing which it would constitute an offence.
The penalty would range from ten thousand dollars to twenty thousand dollars accordingly.
In the case of Carr v the State of Western Australia, it was held by the High Court of
Australia that the analysis of the resources that are helping in the meeting of the objectives f
the legislation needs to be carried out in an in-depth manner that would help in the derivation
of the desired outcomes accordingly that would lead to the identification of the purposes of
the legislation which are dominant in nature accordingly. As a result, it is observed that the
analysis of the resources and materials which imply the meeting of the objectives of the
statute is essential.
Sub-section 1 of Section 1 of the Act of 2017 implies that it is essential to provide a positive
work environment for the members of the Parliament of Australia. Additionally, it is
understood from Sub-section 2 of Section 1 of the Act of 2017 that the work environment
must be consistent with the values of Australia as far as the lifestyles and expectations are
concerned. Furthermore, the promotion of trust is also an important objective as mentioned
earlier with regard to Sub-section 3 of Section 1 of the Act of 2017 .
Extrinsic materials
Section 15 AB of the Acts Interpretation Act of 1901 implies that the explanatory
memorandum and the second reading speech need to be taken into consideration that would
help in the effective results as far as the long run is concerned. It would help in the
understanding of the ordinary meaning of the statute in an efficient manner that would help in
the proper interpretation of the statute accordingly with reference to the objectives under
Section 1 of the Act of 2017 being inconsistent with the second reading speech accordingly
that would possibly lead to the elimination of a positive work culture in the Parliament
accordingly. As a result, it is imperative that the extrinsic material for interpretation would be
helpful in terms of the elimination of the ambiguity of a provision of the statute as far as the

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lucidity in terms of understanding is concerned with reference to the plain meaning rule of
interpretation. Such kinds of extrinsic materials are to be considered accordingly as far as the
addressing of the issues of the provision is concerned that would help in the effective results
in the long run in terms of the facts and circumstances of the given scenario. It would help in
the derivation of the issues in an efficient manner that would lead to the comprehensive
solutions being applied accordingly. The key thing in terms of the reliance of the extrinsic
material would be the understanding of the ordinary meaning of the provision concerned with
reference to the plain meaning rule of interpretation accordingly that would help in the
addressing of the issues in an efficient manner.
The Explanatory Notes would provide a better approach in terms of the interpretation of the
Act of 2017 as far as the understanding is concerned with regard to the ordinary meaning of
the words accordingly (Roach, 2015). It also implies the fostering of a positive work culture
as far as the effective modus operandi of the Parliament of Australia is concerned accordingly
in addition to the pressure on the staffs by the ministers with reference to being inducted into
personal relationships as far as moral turpitude is concerned accordingly.
Context
The context of the Act of 2017 implies that the interpretation is to be done in an ordinary
manner that would help in the understanding of the legislation in a lucid manner through
reading as far as the desired results are concerned.
Broader context
In the case of Singh v Australia, it was held by the High Court of Australia that the broader
context of legislation is influenced by the historical and political factors as far as the
addressing of the issues in an efficient manner is concerned accordingly. As a far as the Act
of 2017 is concerned, it is understood that the public trust is of utmost priority as far as the
long title is concerned which implies the promotion of the interests of the public in an
extensive manner (Walker, 2015). As a result, it is deduced that there is a political context
with reference to the passing of the legislation even though there is no credible evidence that
would support the historical context behind the passing of the legislation.
It is imperative that the ministers have to act in a manner that would help in the maintenance
of public trust in an incredible manner as far as the working upon their interests is concerned.
The imbalances amongst the staff also need to be indentified at the earliest and be addressed
at the earliest as far as the resolution of the issues in an incredible manner is concerned. The
resources need to be taken into consideration with regard to the identification of the purposes
as per the Act of 2017 as far as the effectiveness is concerned thereby leading to the
comprehensive solutions in the long run as far as the beneficial aspects are concerned.
Advice to Amelia
It is imperative that Amelia has acted in contravention of Section 4 of the Act of 2017 with
reference to the facts and circumstances of the case as far as kissing is concerned which
occurred beyond the normal working hours of the Parliament as far as the forging of personal
relationships are concerned. The meaning of personal relationships is under Section 3 of the
Act of 2017 taking into consideration the literal rule of statutory interpretation as far as the

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understanding of the ordinary meaning of the words in a statute is concerned (Gageler, 2015).
It is also observed from the facts and circumstances of the case that the claims of expenses
have been made by Amelia in an unlawful manner that has led to the contravention of Section
7 of the Act of 2017 with regard to the rental of one thousand three hundred twenty nine
dollars per week for eight weeks thereby the total amount being ten thousand six hundred and
thirty two dollars. In addition to the term personal relationship, the terms engaging with is
also applicable with regard to the situation of Amelia as far as personal relationships are
concerned taking account of Section 3 of the Act of 2017 in order to understand the words in
a lucid manner that would help in the addressing of the concerned issues in an efficient
manner accordingly. As a far as Sub-section 3 of Section 4 of the Act of 2017 is concerned,
the burden of proof would lie on Amelia if it is to be justified that the activities concerning
kissing with Bradley beyond the working hours of the Parliament were not unlawful. The
facts of the case imply that the term entering into cannot be applied as far as the plain
meaning rule of interpretation is concerned since the meeting between Amelia and Bradley
was online as understood by Section 3 of the Act of 2017 since Sub-section 2 of Section 4 of
the Act of 2017 implies that kissing leads to the entering into personal relationship as far as
the in-depth analysis of the facts and circumstances of the case are concerned. The lawfulness
of the claim of expenses in terms of Section 7 of the Act of 2017 would be determined as per
Schedule 1 of the Act of 2017. It is imperative that the penalties are to be imposed over
Amelia as stipulated by Sections 4 and 7 of the Act of 2017.
It is observed that the application of the Act of 2017 should be done in an effective manner
that would help in the addressing of the issues in a proper manner as far as the comprehensive
solutions being derive are concerned. It would help in the delivery of justice in an appropriate
manner. In this regard, the application of the Act of 2017 would also aid in the fostering of a
proper work environment in the Parliament that would aid in the maintenance of an incredible
work culture as far as the avoidance of personal relationships are concerned taking account of
the ordinary meaning of the term as enshrined in Section 3 of the Act of 2017 taking account
of the literal rule of interpretation as mentioned earlier. In consideration of the facts of the
case in a detailed manner, it is inferred that the declaration of personal assets also need to be
ensured through the effective enforcement of Section 5 of the Act of 2017 in addition to the
claims for expenses accordingly.
It is also imbibed and understood from Section 3 of the Act of 2017 that exemption is
provided on grounds of being in a personal relationship with a minister. Such kind of
personal relationship can be either partnership or spousal relationship. It is inferred from the
case that Amelia and Bradley have not been engaged in a personal relationship previously. As
a result, under the ambit of Section 3 of the Act of 2017, Amelia cannot be exempted and be
penalised as per Section 4 of the Act of 2017 which implies removal from office for engaging
in a personal relationship as far as the ordinary meaning of the words is concerned.
The concept of staff of parliament as meant by Section 3 of the Act of 2017 implies that the
person who has been appointed by the Parliament of Australia as per the relevant provisions
envisaged in the Commonwealth Employment Act 2005 (Cth) and the Parliament of the
Commonwealth Tour Guide Staff Act 2010 (Cth). In this matter, it is deduced from the facts

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of the case that Bradley is a staff of parliament being a policy advisor to Amelia as far as the
office of Minister for Sport and Recreation is concerned since a policy advisor can be
categorised as an administrative staff.
Answer 2
The amendment of the Act of 2017 would be through the passing of a legislation by the
Parliament of Australia which would be facilitated through the introduction of a bill with
reference to the amendment in an efficient manner as far as the desired results are concerned
which would help in the fulfilment of the purposes and the reasons with respect to the
addressing of the issues in a better manner as far as the conduct of the ministers is concerned
with reference to the modus operandi of the Parliament effectively (Bant, 2015). The main
purpose of the amendment is to improve upon the ambiguities of the Act of 2017 in an
efficient manner that would help in the better outcomes in terms of the functioning of the
Parliament of Australia as far as the ensuring of a better work environment is concerned in
terms of ethics accordingly. Therefore, it is observed that the purpose of the amendment must
help in the supervision and control of the ministers in a better manner. The bill for the
amendment would be the Monitoring of Lobbyists Amendment Bill of 2018.
The Constitution of Australia facilitates for the passing of legislations along with
amendments as far as the main functions of the Parliament of Australia are concerned. The
decision in this regard would be made by the committee constituted by the Parliament of
Australia as far as the proposal of the idea is concerned which would be further incorporated
by the draft bill by the office of Parliamentary Counsel by the virtue of the wordings
suggested accordingly in addition to explanatory notes. The bill would then be introduced in
the House of Representatives in the first reading in which the printing of the bill would take
place. During the second reading of the bill in the House of Representatives, a debate would
take place with reference to the amendment of the bill as far as the discretion of the debate
committee is concerned (Carney, 2015). During the second reading of the bill in the House of
Representatives, the approval of the long title would be made through the voting of the
members with reference to the finality of the bill along with the amendments concerned
which would lead to the completion of the stages of the bill in the House of Representatives,
the lower house of the Parliament of Australia. Thereafter, the bill would be introduced in the
Senate in its first reading. It would be followed by second reading that would involve the
debating over the bill in terms of amendments as far as the debate committee is concerned.
The third reading of the bill would involve voting of the bill along with the amendments
concerned by the members of the Senate as far as the approval is concerned. After the
certification of the bill by the Speaker and the president of the Senate, it would receive Royal
Assent by the Governor-General of Australia thereby becoming a law.

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Answer 3
Constitutional validity
The amendment is constitutionally valid as it involves the supervision of the lobbyists in an
efficient manner in terms of the functioning of the Parliament of Australia in a proper manner
accordingly. The Acts Interpretation Act of 1901 would be applicable since the amendment is
a legislation of the Commonwealth as far as the outcomes are concerned with reference to
statutory interpretation that would ultimately lead to the desired results in terms of the
benefits in the long run accordingly.
Jurisdiction and commencement
The amendment would be enforceable with regard to the situation since as implied by the
detailed analysis of the facts and circumstances of the case, the incident occurred after the
passing of the amendment (Walshaw, 2019). However, Sections 8A -8C of the amendment
need to be considered as far as the detailed analysis of the provisions are concerned with
reference to the commencement after receiving Royal Assent in the manner as purported so
as outlined by the Constitution of Australia. As a result, it is to be seen whether the
amendment has received Royal Assent from the Governor-General so as to determine its
enforceability accordingly.
Advice to Amelia
If it is established that the amendment has received Royal Assent from the Governor-General
of Australia, she would be acting in contravention of Section 8 B and Section 8 C of the
amendment. The penalties would be imposed on her accordingly if it is detected that Bradley
is a lobbyist.
Section 8 B
Section 8 B of the amendment implies that the associating with a lobbyist who is not
registered would involve contravention of the amendment to huge level. It would lead to the
imposition of a penalty involving removal from the position as stipulated. The registration of
a lobbyist would take place through the recording of the details of the lobbyist in register as
understood by Section 8 A of the amendment accordingly (McCrystal, 2019). Sub-section 1
of Section 8 A of the amendment implies that the register has to include the details
concerning the associations along with interactions of the lobbyists with the ministers.
According to Sub-section 2 of Section 8 A of the amendment, the register is to be treated as a
public document with resects to its availability in the website of Parliamentary Regulation of
Integrity and Correctness. The maintenance of the register in a proper and accurate manner
would be the duty of the Board in accordance with Sub-section 3 of Section 8 A of the
amendment. In this regard, it is imperative that the board has not maintained proper
information of Bradley as a lobbyist as far as the analysis of the facts and circumstances of
the case in a detailed manner is concerned. Taking account of the definition of a lobbyist
under Section 4 of the amendment, it is understood that Bradley is not a lobbyist as far as the
plain meaning rule of interpretation is concerned. Instead, Bradley is to be treated as a
government representative within the meaning of Section 4 of the amendment as far as the

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plain meaning rule of interpretation is concerned considering the facts and circumstances of
the scenario accordingly. It would help in the resolution of the issues in an efficient manner.
Section 15 AB of the Acts Interpretation Act of 1901 implies the reliance on extrinsic
materials with reference to statutory interpretation as far as the beneficial outcomes are
concerned. In this regard, the facts and circumstances of the case imply that the extrinsic
materials would be the notes of the speech with regard to the second reading of the bill along
with the recommendations as far as transparency is concerned regarding balance of the
powers of ministers as far as the accessibility to the groups of lobbyists is concerned. The
recommendations of the Senate Committee Report, even though they have not been fully
adopted with regard to the passing of the amendment, they would help in the addressing of
the issues in an efficient manner as far as the plain meaning rule of interpretation is
concerned as far as any legislation involving lobbyists is concerned (Rogers and Maloney,
2017). The validity of the extrinsic materials needs to be taken into consideration with
reference to the ordinary meaning as far as the objectives of the amendment leading to
benefits accordingly. It is imperative that Amelia has not breached Section 8 B of the
amendment as Bradley is not a lobbyist but a government representative as far as Section 4 of
the amendment is concerned taking account of the ordinary meaning of the words
accordingly with reference to the plain meaning rule of interpretation. As a result, the
penalty should not be imposed on Amelia in terms of removal from office for acting in
contravention of the amendment as meant by Section 8 B of the amendment accordingly. If
Bradley was classified as a lobbyist who was not registered as meant by Section 4 and
Section 8 A of the amendment respectively, Amelia would have been acting in violation of
the amendment as understood by Section 8 B of the amendment and she would be removed
from her office accordingly even though the Board did not register him as far as the accuracy
of the details if a lobbyist being maintained in a proper and appropriate manner is concerned.
Section 8 C
As a far as Section 8 C of the amendment is concerned, the minister must maintain the
records of the meetings, engagement and interactions officially held in a ministerial diary as
far as the effective outcomes are concerned accordingly. Failure to do so would attract
penalties as applicable with reference to the resolution of the issue in an efficient manner as
far as the beneficial outcomes are concerned accordingly. As a result, it is imperative from
the facts of the case that Amelia has acted in breach of Section 8 C of the amendment.
Answer 4
The Board of Parliamentary Regulation of Integrity and Correctness is established in
accordance with Sub-section 1 of Section 6 of the Act of 2017. The responsibility of the
Board implies the supervision in terms of the ensuring of the maintenance of Integrity and
Correctness as implied by Sub-section 2 of Section 6 of the Act of 2017. It is imperative that
the Board has to act in manner that would help in the maintenance of a proper work culture at
the Parliament of Australia that would help in the following of ethics by the members of the
Parliament accordingly (Tronson, 2016). Section 8 of the Act of 2017 implies that the Board
has to maintain a register with regard to the records of the interests of the ministers

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accordingly. Section 8 A of the amendment implies that the register for lobbyists also need to
be maintained accordingly. As understood by Sub-section 1 of Section 33 of the Acts
Interpretation Act of 1901, if a function or duty or power is conferred upon an entity, the
power may be exercised and the function or duty needs to be performed by the entity
concerned as per the requirements stipulated or prescribed accordingly. Sub-section 2A of
Section 33 of the Acts Interpretation Act of 1901 implies that the term “may” would imply
the discretion of the concerned person or authority to perform the act or obligation as implied
by the respective legislation accordingly (Crawford et al., 2017). It is imperative that it is
mandatory for the Board to undertake the obligations and responsibilities as stipulated by
Section 8 of the Act of 2017 along with Section 8 A of the amendment as far as the
maintenance of registers is concerned accordingly. As a result, it is imperative that stringent
action needs to be taken against the Board as it has failed to carry out the duties and
obligations stipulated under Section 8 of the Commonwealth of Australia Members of
Parliament Integrity and Correctness Act of 2017 (Cth) along with Section 8 A of the
amendment taking account of the facts and circumstances of the case in a detailed manner.
Therefore, the provisions regarding the same are to be applied in an efficient manner as far as
the action being undertaken against the Board is concerned with reference to the failure in
maintenance of the registers as required since as implied by Section 33 of the Acts
Interpretation Act of 1901, the maintenance of registers on part of the Board is a requirement
and not a discretion as far as the meaning of the terms power, function and duty are
concerned accordingly. Such kinds of measures and steps would help in the resolution of the
problems in an efficient manner in addition to the facilitation of the ease for the searching of
records when required in terms of the respective situation accordingly. It would also lead to
the comprehensive outcomes being derived in addition to the addressing of the issues in a
timely manner.

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Reference List
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Bant, E., 2015. Statute and common law: Interaction and influence in light of the principle of
coherence. UNSWLJ, 38, p.367.
Carney, G., 2015. Comparative Approaches to Statutory Interpretation in Civil Law and
Common Law Jurisdictions. Statute law review, 36(1), pp.46-58.
Crawford, L.B., Boughey, J., Castan, M. and O'Sullivan, M., 2017 . Public Law and Statutory
Interpretation: Principles and Practice. Federation Press.
Gageler, S., 2015. Legislative intention. Monash UL Rev., 41, p.1.
McCrystal, S., 2019. Why is it so hard to take lawful strike action in Australia?. Journal of
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Roach, K., 2015. Comparative reflections on miscarriages of justice in Australia and
Canada. Flinders LJ, 17, p.381.
Rogers, N. and Maloney, M., 2017 . The wild law judgment project. In Law as if Earth Really
Mattered (pp. 3-18). Abingdon: Routledge.
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Law Review, 44(2), pp.227-255.
Staszewski, G., 2015. The Dumbing Down of Statutory Interpretation. BUL Rev., 95, p.209.
Tronson, B., 2016. Statutory interpretation: Context and beneficiality. LSJ: Law Society of
NSW Journal, (27), p.82.
Walker, C.J., 2015. Inside agency statutory interpretation. Stan. L. Rev., 67, p.999.
Walshaw, C., 2019. Recent Developments in Statutory and Constitutional
Interpretation. Statute Law Review, 40(1), pp.1-12.

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