O’REGAN J and SACHS J restrictive interpretation which would narrow its ambit and bring it within constitutional limits, such interpretation being achieved without undue strain. The question is whether the phrase “unlawful sexual intercourse or indecent act for reward” is capable of being read to include only activity ordinarily understood as prostitution. In other words, is the phrase reasonably capable of being read so as to cover only commercial sex, that is, sex where the body is made available for sexual stimulation on a paid basis? We think there are strong contextual pointers in favour of the more restrictive reading. [49] The heading to the section includes the words: “persons living on the earnings of prostitution”. In President of the Republic of South Africa v Hugo,16 this Court held that it was legitimate for a court interpreting a statute to have regard to the heading of a legislative provision. In this case, the heading of section 20 makes it clear that the section is dealing with persons living on the earnings of prostitution. This suggests that a narrow meaning related to the heading should be given to section 20. If one reads the criminal prohibition contained in section 20(1)(aA) in the light of the heading, one would attribute a meaning to the section which renders criminal the conduct of those who earn their living from prostitution, or commercial sex. It may be difficult in some circumstances to apply this rule and to determine whether or not the conduct concerned is sufficiently commercialised and indiscriminate as to qualify as prostitution. This remains a matter of application, however, not one of definition and is best undertaken on a caseby-case basis by the courts. We accordingly hold that in this respect the section is reasonably capable of a restrictive interpretation. 16 1997 (4) SA 1 (CC); 1997 (6) BCLR 708 (CC) at para 12. 28