Background
The Environmental Control Act (the Act), was introduced into WA in 2016. The Act provides local government control to regulate pollution into the marine environment and terrestrial waterways in the South West area. It was established as a response to the increasing levels of aluminium and other metals found in soil, vegetation and waterways. The delegation of power to local authorities is broad and gives the local authorities the ability to create and enforce local laws appropriate to the particular needs and resources available in their governing area. In January 2016, Daisy was approached by a local government environment officer named John Ruth. Daisy was a university student that used disposable spray paint cans to create modern art inspired by the Gracetown bush retreat. At the time that she was approached, Daisy was in the process of cleaning a spray paint can, Psychedelic Purple which contained magnesium particles. When cleaning these cans, Daisy had to hold them upside down and spray out any excess repellent. Upon seeing this, John Ruth was certain that some of this paint had landed on her outdoor shower area which was located near her kitchen. John Ruth issued a notice that there had been a breach of Augusta Margaret River Shire Council local law that relates to the discharge of metals and metallic particles into soil, areas of vegetation, waterways, sewers, drains or similar areas. This law is followed by a significant fine of $3000. Daisy argues that the law does not apply when an insignificant amount of particles is discharged into a water storage container. The following provides an outline of relevant legal concepts and approaches to determine the validity of Daisy's argument. Statutory Interpretation
Statutory interpretation is a method used by courts to interpret and apply legislation. It is necessary for legislations to have rules as in some cases, words have more than one meaning. These rules help define these meanings and assist courts interpreting alleged breaches (Subhyanka Rao 2014).

Statutory Rules
The use of specific statutory rules by Parliament is important in assisting statutory interpretation. Section 18 of the Acts Interpretation Act 1901 (Cth) (“the Act”), orders that the "interpretation of a provision of a written law, a construction that would promote the purpose or object underlying the written law… shall be preferred to a construction that would not promote that purpose or object." Most statutes typically include a section defining certain terms that provide assistance for the interpretation of that particular statute. Furthermore, it is found in section 19 of the Act, that there are specific rules which can be used as a guide to interpret the legislation in court. Common Law Rules
In the past, the rule of statutory interpretation for common-law has been "look at the words of the Act". This is a result of the assumption statutes do not require further analysis for meanings as statutes alone serves as an adequate guide. These approaches to interpreting statutes are four-fold. The literal approach emerged from the Sussex Peerage Case (1844) and gives an "ordinary, plain, and natural" (literal) meaning to rules of legislation. Secondly, the mischief rule was established in Heydon's Case (1584) and used in situations where there is ambiguity in a statute in order to interpret the intention of the legislators to remedy. This rule is the oldest of common law rules. Thirdly, the golden rule which was first expressed in the case of Grey v. Pearson (1857) stated the grammatical approach, is the most commonly used approach in Australia as the mischief and golden rules were being seen as subsidiary to the literal rule. However, during the 1970s, the emergence of the Acts Interpretation Act 1901 s. 15AA caused the overturning of literalism by the courts. Additionally, there are three rules of language used by the courts in order to assist in interpreting statutes. These rules of language are called ejusdem generis and are often referred to as intrinsic or internal aids. These rules are used to interpret statutes that include lists of particularised things and then refers to them in general (Rastra Bimochan Timalsena 2012). This rule was expressed in the case of Powell vs Kempton Park Racecourse Co Ltd (1899), where a component of the statute stated "house, office, room or any similar place" was interpreted ejusdem generis. The common factor that brought these words together were perimeters with walls and a roof, hence "any similar place" must be interpreted to include only roofed areas. Application of Statutory Interpretation
The Augusta Margaret River Shire Council local law 59 states that "a person shall not dispose of metals or metallic particles into soil, areas of vegetation, waterways, sewers, drains or similar areas." It was intended by the Parliament that the law would provide adequate protection for the flow of pollution into the environment within local government jurisdiction. This law was made pursuant to the Environmental Control Act (2016) WA in which section 43 states that "Councils may make local laws" for the purpose of "regulating pollution and environmental protection". In this case, statutory interpretation must be applied to the alleged breach by Daisy. The literal approach to statutes require words to be given their natural and ordinary meaning. Thus, legislations must be read literally and should not require any further analysis for different meanings. When the words of local law 59 is examined, it is clear that the intention was that disposal of any pollution in the form of metals or metallic particles is to be prohibited. The term "dispose" in its ordinary definition refers to the act of allowing to escape and failure to prevent matter to be discharged, deposited or allowed to escape (Environmental Protection Act 1986). It was admitted by Daisy that paint was discharged in the process of cleaning her spray paint cans. Hence, taking the literal approach, it was under Daisy's control to allow the paint escape and therefore, this act of disposal contributed to the pollution of the area. This literal approach was used in the case of IRC vs. Hinchy (1960) AC 748 where a taxpayer had filed an incorrect tax return. This case concerned the Income Tax Act 1952, where he was subject to a fixed penalty plus "treble the tax". It was intended by Parliament that the penalty should be based on the unpaid portion of the tax, however the House of Lords used the literal approach and determined the tax payer responsible for paying three times the entire tax. The act passed by Parliament was introduced to combat the increase of pollution in the South West area. It provides the local council the power to create laws in order to regulate pollution and protect the environment. The aim is to counteract this new threat of metal pollution in soils, vegetation and waterways. As Daisy argues that the local law 59 does not apply to 'insignificant" amounts of discharge into a water storage container on a private residence, the mischief rule could be applied to determine whether there was a breach of law. It is clear that the parliament wants to eliminate pollution, hence any amounts of discharge in metal particles will contribute to pollution in the environment as a whole. Furthermore, it does not matter that it discharged on a private residence, as particles allegedly landed in the outdoor shower which is connected to a plastic pipe used to water her plants and shrubs. Ultimately, this will contaminate the soil as well as vegetation, which are both prohibited by law. An example of the mischief rule is in the case of Smith v Hughes (1960) where six prostitutes argued they did not breach the law that prohibits prostitutes to loiter or solicit in a street or a public place as they were not on the streets, but tapping on the windows of their balcony. The judge determined there was little matter despite where they were as the result of their actions were not aligned with the intentions of the Act. When Daisy receive the summons notice, she was sure the law did not apply since the paint allegedly landed in a water storage container at her house. In this case, the ejusdem generis rule would be the most effective for determining whether Daisy's argument is valid or not. The rule of ejusdem generis is used when statutes include particularised lists with terms that are of the same kind or nature. In this case "areas of vegetation, waterways, sewers, drains or similar areas" all share similar characteristics of being areas where water flows through. Although a water storage container is not expressly mentioned in the statute, it is still an area where there is water flow. Hence, Daisy's argument may be deemed invalid as it could be interpreted that "similar areas" include water storage containers. The purposive approach relies on analysing the wishes of Parliament for interpretation. When applying this approach, the intentions of parliament would be that authoritative power be applied in a reasonable and just manner to those breaching the law. Hence, the law would not be intended to be applied in an injudicious and cavalier manner. However, it is clear in this case that the local environment officer, John Ruth was unable to provide evidence of the alleged pollution and a direct link of the paint falling into the outdoor shower. In other words, it was merely his opinion and should not be used as a ground for the alleged breach. It would also be fundamentally at odds with the intention of the Parliament and the Act. Therefore, while it appears that there was a literal breach of the act, applying the purposive approach it is arguable that the breach was not an act contemplated by Parliament and therefore a literal approach is not warranted.

Conclusion
It is important to use statutory interpretation as a guide to determine the underlying meanings to statutes and legislation. This includes applying the common law rules of statutory interpretation against the present case. As discussed above, the literal and mischief approach to the statute determines Daisy to be guilty as she has offended the intentions of the local law 59 which prohibits the disposal of metal and metallic particles. Furthermore, Daisy’s argument may be deemed invalid when the rule of ejusdem generis is applied. This rule directs that pollution in water storage containers are included in the law established by the Augusta Margaret River Shire Council. Though, if the purposive approach is applied, it can be argued that the notice authorised by environmental officer John Ruth was done in a manner which was injudicious and cavalier. This means the notice was unwarranted and excessive as it was an insignificant amount of paint she had discharged during the process of cleaning her spray paint cans.