reasonableness: Dunsmuir v. New Brunswick,  1 S.C.R.
190,  S.C.J. No. 9, 2008 SCC 9.
 The Divisional Court did not address the constitutional
validity of s. 12(2)(f.1), apparently concluding that the issue was
being addressed in other proceedings. This assumption appears
to have been erroneous. A notice of constitutional question was
served in these proceedings. The parties invited us to address
the issue. In the circumstances, as this court has a complete record and has received written and oral submissions from both
parties on the issue, it is my view that the constitutional issue
should be addressed.
(2) Unreasonable and arbitrary demand for security
 The interpretation of s. 12(2)(f.1) advanced by the appellant in the Divisional Court, and rejected by that court, was
not pursued before us. Instead, the appellant argues that
s. 12(2)(f.1) only applies to tobacco packaged for retail and that,
in any case, as a matter of fact, its product was not UFCT. Thus,
the appellant says, it was improper for the minister to rely on
the “other tobacco” category in the appellant’s monthly returns
when most of this tobacco was allegedly not UFCT.
 I agree with the minister that there are several answers
to this argument. It was reasonable for the minister to calculate
the amount of security with reference to the exported tobacco
that was included in the “other tobacco” category.
 First, and in my view, foremost, the appellant’s interpretation of the statute is illogical. It submits that the definition of
UFCT, when read with the definition of “marked fine cut tobacco”, means that UFCT must be in a “box, tin or other container”
used for retail sale. The appellant argues that since its export
tobacco is not packaged in this manner, it is not UFCT.
 As expressed in the appellant’s factum, the argument is:
“Unmarked fine cut tobacco” is defined in the TTA as “fine cut tobacco that
is not marked fine cut tobacco”. “Marked fine cut tobacco” is defined as “fine
cut tobacco in a package that is marked or stamped with an indicium as
required under the regulations”. A “package” is defined as “a box, tin or
other container in which a tobacco product is sold at retail”. Therefore,
“unmarked fine cut tobacco” is fine cut tobacco in a box, tin or other container in which a tobacco product is sold at retail that is not marked or
stamped with an indicium as required under the regulations.
(Emphasis in original)
 In my view, this interpretation distorts the language of
the statute and is plainly wrong. The modern approach to statutory interpretation requires that “the words of an Act are to
be read in their entire context and in their grammatical and