“The headings prefixed to sections or sets of sections in some modern statutes are regarded as preambles to those sections. They cannot control the plain words of the statute, but they may explain ambiguous words ….” P. St. J. Langan, Maxwell on the Interpretation of Statutes 11 (12th ed. 1969).
heading
heading. A brief title or caption of a section of a statute, contract, or other writing.