Metro Can Construction Ltd. v. The Queen, 2000 DTC 6495, 2001 FCA 227 -- summary under Subsection 45(3)

McDonald J.A. indicated that although Bathurst Paper Limited v. New Brunswick [1972] SCR 471 indicated that subsequent amendments might be considered as part of the legislative history bearing on the construction on the amended statute, this did not mean, in light of s. 45(3) of the Interpretation Act, that subsequent amendments could themselves serve as a declaration concerning the previous state of the law. Accordingly, he found that subsequent amendments to s. 80 of the Act were only relevant to interpreting the section as it previously read insofar as they were part of the general legislative history of the section.