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ARTICLE · 06 DECEMBER 2018

NSW Government Bulletin: a zeugma in statutory interpretation

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In this decision, the NSW Court of Appeal examined the construction of the section, including the impact of a zeugma.

AustraliaGovernment, Public Sector

There's a zeugma in my statute

In Olefines Pty Ltd v Valuer-General of New South Wales [2018] NSWCA 265, the NSW Court of Appeal (the Court) dismissed an appeal challenging the valuation of two parcels of land. The parties' valuers had each employed a different valuation methodology, which arose from the complexity of section 6A of the Valuation of Land Act 1916 (NSW) (Valuation Act). In its decision the Court examined the construction of the section, including the impact of a zeugma in section 6A(2).

A zeugma is a language device where one word is used to modify two other words, albeit in different ways, such as in "She broke his car and his heart."

How does the Court deal with a zeugma in a statutory interpretation context?

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