Long titleInternal aidsHouse of Lords

Attorney-General v Prince Ernest Augustus of Hanover

[1957] Appeal Cases 43619571 min read
The case in brief30-second read
Facts
Prince Ernest Augustus, a descendant of Princess Sophia of Hanover, claimed British nationality. Princess Sophia Naturalisation Act, 1705 conferred natural-born status on descendants of Sophia.
Issue
Whether the long title of a statute can restrict the plain meaning of its enacting words.
Held
The long title is part of the Act and is a legitimate aid to construction.
Principle
The long title of an Act is part of the Act and may be used as an aid to interpretation. However, where the enacting words are clear and unambiguous, neither the long title nor the preamble can restrict or qualify them.
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Facts

  • Prince Ernest Augustus, a descendant of Princess Sophia of Hanover, claimed British nationality
  • Princess Sophia Naturalisation Act, 1705 conferred natural-born status on descendants of Sophia
  • Crown argued the long title showed Parliament intended only to secure Protestant succession, not to confer nationality on foreign princes generations later

Issue

  1. Whether the long title of a statute can restrict the plain meaning of its enacting words.

Held

  • The long title is part of the Act and is a legitimate aid to construction
  • But where the enacting words are clear and unambiguous, no external element (title, preamble) can cut them down
  • The 1705 Act plainly conferred British nationality on all lineal descendants of Sophia
  • Prince's claim upheld

Ratio decidendi

The long title of an Act is part of it and may be considered in construction. But if the enacting words are clear, neither the long title nor the preamble can restrict or expand their natural meaning. Clear enacting words prevail over any indication in the title or preamble.

Exam use

How to use it in an answer

  • Authority for role and limits of long title as internal aid
  • Shows hierarchy: enacting words > title/preamble
  • Key line: "In AG v. Prince Ernest Augustus (1957), the House of Lords held that the long title is part of the Act and aids interpretation, but cannot restrict clear enacting words."

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Citation

Attorney-General v. Prince Ernest Augustus of Hanover [1957] Appeal Cases 436

Reported: [1957] AC 436. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.