292 THE ADVOCATE
VOL. 76 PART 2 MARCH 2018
tion of Equality”,194 was cited by the Supreme Court of Canada in Eldridge v.
British Columbia (Attorney General).195
The B.C. Court of Appeal in B.C. Dev. Corp. v. NAB Hldg. Ltd.196 referred to
three Advocate articles as discussing “the status of the legislative history of
an enactment, as a tool of interpretation, following a statutory consolidation”:
J.W. Lawrence’s 1982 article called “The Identification and Interpretation
of Revised Statutes”,197 Allan R. Roger’s article of the same year called
“The Revised Statutes Alive and Well?”,198 and, again from 1982, H.M. Thornton’s
“More About Revised Statutes”.199
The meaning of “special damages” was examined partly in light of Leon
Getz, Q.C.’s 1976 article entitled “Pre-Judgment Interest”200 in Baart v.
Kumar, in the B.C. Court of Appeal.
Analyzing the history of forestry law and leasing practice in the province,
the B.C. Supreme Court cited Richard Campbell, “The Development of the
New Forest Act”202 in MacMillan Bloedel Ltd. v. Mullin.203
The B.C. Court of Appeal in Workshop Holdings v. CAE Machinery Ltd.204
described the B.C. Supreme Court in Swamy v. Tham Demolition205 as having
been “influenced” in part by Diana Belevsky and Chris Tollefson’s 1997
article, “Bill 26 Arrives”.206 The Supreme Court’s reliance on that article
was also noted in No. 158 Seabright Holdings Ltd. v. Imperial Oil Limited-
Compagnie Petroliere Imperiale Ltee.207
If the effectiveness of a good old-fashioned “Grumble” were ever doubted,
one need only look to the effect of Michael C. Woodward’s grumbly November
2015 contribution, “The Curse of the ‘Corrected Judgment’”.208 Having
decided to “crunch some numbers”, Woodward discovered that over the past
three years, the B.C. Supreme Court and B.C. Court of Appeal had issued
corrected judgments in 7.8 per cent and 6.8 per cent of decisions, respectively.
Pulling no punches, Woodward suggested that “in terms of attention
to copy editing, the court is not exactly over-egging the pudding”. Indeed,
Woodward added, “if over my career I had to formally correct 6.8 per cent
of the legal opinions I delivered, the bulk of my clients would be of the