Of course, Lord Hoffmann never said that words have no meaning independently of context. Neither did he belittle dictionaries and grammars as tools of interpretation. As is apparent from his judgment in Mannai Investment, he accepted that words do have dictionary or ordinary meanings. His main point was that it was important to:

“distinguish between the meanings of words and the question of what would be understood as the meaning of a person who uses words. The meaning of words, as they would appear in a dictionary, and the effect of their syntactical arrangement, as it would appear in a grammar, is part of the material which we use to understand a speaker’s utterance. But it is only a part; another part is our knowledge of the background against which the utterance was made.”

Furthermore, he rightly stressed in his leading judgments that there will usually be no answer to the solution derived from giving the words their ordinary or conventional meaning. That is the meaning that the document will convey to a reasonable person unless, for example, there is something in the background to suggest that something went wrong with the language and therefore that the parties can reasonably be taken to have intended a different meaning. Cf his judgment in Bank of Credit and Commerce International SA v Ali [2002] AC 251, [39] (“the primary source for understanding what the parties meant is their language interpreted in accordance with conventional usage”). He was the dissenting judge in this case and criticised the majority (at [37]) for giving “too little weight to the actual language and background” of the document in question.