ABSTRACT
When an Act is divided into parts the custom today is to put a heading to each part. Similarly, when the sections within a part are divided into divisions the custom is to put a heading to each division.1 Curiously, the use of headings in Acts of Parliament did not start until 1845. In Acts passed thereafter the headings can be said to ‘constitute an important part of the Act itself’.2 When an Act does have headings, any of the sections under such a heading must be interpreted in the light of all the sections under that heading.3
