Inland Revenue Commissioners v Frere

• "Interest" appeared in several sections of the Income Tax Act
• In some sections it clearly had a broad meaning; in others, a narrow one was argued
• Revenue contended one uniform meaning should be applied throughout

1. Whether the same word must bear the same meaning in every section of the same statute.

• Presumption of uniform meaning exists (consistency in statutory language)
• But the presumption is rebuttable by context
• Where the legislative purpose of different sections requires it, the same word may bear different meanings
• Context prevails over mechanical uniformity

There is a presumption that the Legislature uses the same word with the same meaning throughout a statute. But this is only a presumption. It yields where the context of a particular provision, or the purpose of the section, plainly requires a different shade of meaning.