McCallum v Projector Films [2026] FCA 173
After setting out the basics of our ‘modern approach’ from Palmanova, the court (at [150-151]) provided guidance on the proper use of dictionaries.
The court said that ordinary meaning ‘is not necessarily divined from a dictionary’. A ‘familiar difficulty’ is that dictionaries specify a range of meanings (or senses) rather than any particular meaning in context. Dictionaries are useful in the identification of possible meanings, but they tell us nothing about context and they are no substitute for interpretation. Finally, beware of treating words used in dictionary definitions ‘as if they are synonyms for the word in its statutory context’9.
This principle is from Episode 131 of interpretation NOW!
Footnotes:
9 Martinez [2013] FCA 439 [68] quoted, cf Supaphien [2026] ACTCA 5 [62].