70 CONSTITUTION OF MARYLAND [Art. 3]

The first clause of this section is directory and not mandatory; hence an act, the
title of which is "An Act—————Telegraph Companies, etc. " (describing the subject
of the act), and then proceeding, "Be It Enacted by the People of the State of Maryland
Represented in the General Assembly, " is valid. Postal Telegraph Co. v. State, 110
Md. 608; Prince George's County v. B. & O. R. Co., 113 Md. 182; McPherson v.
Leonard, 29 Md. 386 (cf. dissenting opinion); Levin v. Hewes, 118 Md. 635. And see
Maxwell v. State, 40 Md. 301 (dissenting opinion); Williams v. Broening, Mayor, 135
Md. 232.

The portion of this section providing that an act shall be divided into articles and
sections, is directory and not mandatory. Anderson v. Baker, 23 Md. 585 and 570;
Dorchester County v. Meekins, 50 Md. 45.

This section will be liberally construed to effectuate and not to destroy the legis-
lative will. The portion of this section directing public general laws to be enacted in
articles and sections in the same manner as the code is arranged, held to have been
substantially complied with. Hardesty v. Taft, 23 Md. 525.

The portion of this section (as it stood in the Constitution of 1864), providing that
"No law, etc., shall be revived, amended or repealed by reference to its title or section
only, " held not to defeat the repeal of a pre-existing law by the implication resulting
from a subsequent inconsistent or contradictory enactment. Purpose of the above
portion of this section. Davis v. State, 7 Md. 158.

Under this section and the legislative practice, where the repealing law contains a
substantial re-enactment of the previous law, the operation of the latter continues
uninterrupted. This principle applied to act of 1900, ch. 207, repealing and re-enacting
the act of 1888, ch. 395, which in turn repealed and re-enacted the act of 1884, ch. 485,
all dealing with the redemption of ground rents. Swan v. Kemp, 97 Md. 691.

In the light of art. 1, sec. 8 of the An. Code, the act of 1916, ch. 704, sec. 184, pro-
viding for builders' licenses does not violate the portion of this section providing
that a law shall embrace but one subject which shall be described in the title. Ap-
pellee's contention was based on the fact that the title related to "Construction Firms
or Companies, " while the section was applicable to any "person, firm or corporation. "
State v. Case, 132 Md. 273.

Title need not contain an abstract of the bill nor give its provisions in detail, but
it must not be misleading by apparently limiting the enactment to a much narrower
scope than the body of the act; nor ought it to be such as to divert attention from
the matter contained in the body of the act. Purpose of this section. See notes to art
49, sec. 7, of the Code. State v. King, 124 Md. 497.

In order to comply with this section, though the title need not give an abstract of
the act, yet it must sufficiently describe the subject-matter and must not be misleading
by apparently limiting the enactment to a much narrower scope than the body of the
act embraces. A section which was attempted to be repealed and re-enacted with
amendments by an act neither the title nor enacting clause of which referred to such
section, held void. Baltimore v. Williams, 124 Md. 510.

The title of the act of 1910, ch. 180, creating the public service commission, held
sufficient under this section; purpose and construction of this section. See notes to
art. 23, sec. 347, of the Code. Thrift v. Laird, 125 Md. 69.

Title of the act of 1912, ch. 32, restricting the liability of Baltimore city for injuries
due to the unsafe condition of the Patapsco River, is not in violation of this section
Foard Co. v. Maryland, 219 Fed. 828.

Title of Baltimore city ordinance, No. 332, approved July 25, 1913, prescribing cer-
tain regulations of the markets in said city, held sufficient under this section, since it
repeals and reordains with amendments, certain sections of art. 23 of the Baltimore City
Code. Baltimore v. Wollman, 123. Md. 313.

Act of 1914, ch. 250, authorizing the mayor, etc., of Mount Ranier to issue bonds
and use the proceeds for constructing a sewer and water system, etc.. held invalid,
because its title was defective under this section. Cases reviewed. Weber v. Probey,
125 Md. 549.

Under a title calling for one bill, a different act may not be validly passed. Thrift
v. Towers, 127 Md. 60.

This section referred to in stating that where the meaning of an act is doubtful, its
title may be referred to. Maxwell v. State, 40 Md. 306 (dissenting opinion).

Cited but not construed in Foote v. Claggett, 116 Md. 232; B. & O. R. R. Co. v.
Waters, 105 Md. 416; Prince George's County v. Laurel, 70 Md. 445.

Act 1924, ch. 495, giving certain riparian owners in Dorchester County certain
fishing rights upheld; reference in title to article and section sufficient. Dean v.
Slocum, 149 Md. 580.

Title act 1927, ch. 359, providing for construction of roadways, sewers, etc., in
Chestertown, defective in failure to refer to creation of special commission; act void.
Culp v. Commrs. of Chestertown, 154 Md. 622.

Title of ordinance submitting Baltimore Airport Loan to voters, held sufficient. See
notes to art. 11, sec. 7, of Constitution. Douty v. Baltimore, 155 Md. 137.

Ordinance of Baltimore regulating slaughter houses, etc., sufficiently described in
title. Baltimore v. Bloecher, 149 Md. 659.