Singular and plural

Taylor v The Queen [2020] VSCA 50

This is a rare case where contrary intention rebuts the presumption that the singular includes the plural12.  T was charged with trafficking in a ‘drug of dependence’13 – ‘anabolic or steroid agents’, which is a class of drugs rather than an individual drug.  The question was whether a class of drugs (plural) can be a drug (singular) under the provision.

The court (at [65]) said ‘no’,  and T was acquitted.  The provision emphasised singularity (‘a substance … a drug’), a theme continued throughout the Act – cf offences where inclusion of the plural was deliberate and explicit.  iTip – assess contrary intention by reference to text, context and purpose.

This principle is from Episode 62 of interpretation NOW!


12 s 37 Interpretation of Legislation Act 1984 (VIC), cf Pearce IAIA (at [4.7]).

13 s 71AC of the Drugs, Poisons and Controlled Substances Act 1981 (VIC).