Report No. 60
8.5. "Clear days".-
(a) As regards the phrase "clear days", which is often employed in statutes, it is well settled that where this phrase is used, the time is to be reckoned exclusive of both the first and the last day.1
(b) Where, however, the expression used is something else than "clear days" (or "at least" or "not less" so many days), the general rule obtaining at present seems to be that the first day is included, and the last day excluded2
1. Stroud Judicial Dictionary, (1952), Vol. 1, p. 500, item No. 16.
2. Rudcliffe v. Bartholomaew, (1892) 1 KB 161.
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