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Statutory Interpretation - Statute Read as a Whole. Pepa v. Canada (Citizenship and Immigration)
In Pepa v. Canada (Citizenship and Immigration) (SCC, 2025) the Supreme Court of Canada considered the 'statute read as a whole' principle of statutory interpretation:[107] Words take their colour from their surroundings (J. Willis, “Statute Interpretation in a Nutshell” (1938), 16 Can. Bar Rev. 1, at p. 6). In the world of statutory interpretation, there is a presumption “that the provisions of [a statute] are meant to work together . . . as parts of a functioning whole” (R. Sullivan, The Construction of Statutes (7th ed. 2022), at p. 323), which form together into a rational, internally consistent framework (Heritage Capital Corp. v. Equitable Trust Co., 2016 SCC 19, [2016] 1 S.C.R. 306, at para. 28). . Imperial Oil Limited v. Haseeb
In Imperial Oil Limited v. Haseeb (Ont CA, 2023) the Court of Appeal considered the 'wholistic' aspect of statutory interpretation doctrine:[131] However, for purposes of statutory interpretation of the meaning of discrimination on the basis of “citizenship” in s. 5 of the Code, s. 5 must be read in the context of the Code as a whole, including s. 16: Rizzo, at para. 21; Ruth Sullivan, The Construction of Statutes, 7th ed. (Toronto: LexisNexis Canada, 2022) at § 13.02[3]. As the Supreme Court explained in Heritage Capital Corp. v. Equitable Trust Co., 2016 SCC 19, [2016] 1 S.C.R. 306, at para. 28, provisions of a statute are presumptively intended to work together as a whole:There is a presumption of statutory interpretation that the provisions of a statute are meant to work together “as parts of a functioning whole” and form an internally consistent framework. In other words, “the whole gives meaning to its parts”, and “each legal provision should be considered in relation to other provisions, as parts of a whole”. [Citations omitted.]
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