This case, dealt with in Episode 59, also contains a punctuation issue3 – that being, whether a semicolon separated 2 discrete things within a schedule; or required them to be read together. Ward CJ (at ) observed that semicolons may replace ‘and’ as a ‘hierarchically superior punctuation mark if the reader is not to be momentarily puzzled or misled’4.
It was held (at ) that context and purpose confirmed that the semicolon indicated separate things rather than a singular description5. Past times were marked by a distinct hostility to punctuation. The modern position is – don’t ignore it, but make sure it is ‘used consciously and not haphazardly’6.
This principle is from Episode 60 of interpretation NOW!
3 cf Episode 13, Pearce 9th ed (at [4.76-4.78]).
4 Savvin  FCA 478 (at ), Quirk Comprehensive Grammar (at 1623).
5 cf Scalia & Garner (at 164), discussing Hill v Conway 463 A 2d 232 (1983).