The Commissioner of Patents has raised the question whether, under section 32(3) of the Patents Act 1903, a corporation may be a 'person' competent to make application for a patent.

Section 22 of the Acts Interpretation Act 1901 provides that 'In any Act, unless the contrary intention appears, "person" . . . shall include a body . . . corporate as well as an individual'.

In my opinion 'person' in section 32(3) of the Patents Act includes corporation-though I do not think that a corporation could under any circumstances be 'the actual inventor' within the meaning of paragraph (a).

[Vol. 4, p. 405]