What is the modern view on the use of 'marginal notes' appended to sections of an Indian statute as an aid to interpretation?

1. The ICSI text records: 'In England, the disposition of the Court is to disregard the marginal notes. In our country the Courts have entertained different views.' 2. The **weight of authority is in favour of the view that the marginal note appended to a section cannot be referred to for the purpose of construing the section** — *Balraj Kumar v. Jagatpal Singh, 26 All. 393*; reaffirmed by Patanjali Shastri, J. in *C.I.T. v. Anand Bhai Umar Bhai, A.I.R. 1950 S.C. 134*. 3. *However*, marginal notes **appended to Articles of the Constitution** have been held to constitute part of the Constitution and may furnish *prima facie* clue to meaning (e.g. Article 286). 4. Recent decisions (*Sarbajit Rick Singh v. Union of India, (2008) 2 SCC 417*) permit reference to a marginal note when a section is sought to be interpreted differently. _Source: ICSI CS Executive — Lesson 3, 'Internal Aids — Marginal Notes', pp. 92-93._