the statutory text. Historical interpretation: using the legislative history, to reveal the intent of the legislator. Systematic interpretation: considering the context of provisions, if only by acknowledging in which chapter a provision is listed. Teleological interpretation: considering the purpose of the statute (), as it appears from legislative history, or other observations. It is controversial whether there is a hierarchy between interpretation methods. Germans prefer a "grammatical" (literal) interpretation, because the statutory text has a democratic legitimation, and "sensible" interpretations are risky, in particular in view of German history. "Sensible" means different things to different people. The modern common law perception that courts actually make law is very different. In a German perception, courts can only further develop law (). All of the above methods may seem reasonable: It may be considered undemocratic to ignore the literal text, because only that text was passed through democratic processes. Indeed, there may be no single legislative "intent" other than the literal text that was enacted by the legislature, because different legislators may have different views about the meaning of an enacted statute. It may also be considered unfair to depart from the literal text because a citizen reading the literal text may not have fair notice that a court would depart from its literal meaning, nor fair notice as to what meaning the court would adopt. It may also be unwise to depart from the literal text if judges are generally less likely than legislatures to enact wise policies. But it may also seem unfair to ignore the intent of the legislators, or the system of the statutes. So for instance in Dutch law, no general priority sequence for the above methods is recognized. The freedom of interpretation varies by area of law. Criminal law and tax law must be interpreted very strictly, and never to the disadvantage of citizens, but liability law requires more elaborate interpretation, because here (usually) both parties are citizens. Here the statute may even be interpreted in exceptional cases, if otherwise a patently unreasonable result would follow. International treaties The interpretation of international treaties is governed by another treaty, the Vienna Convention on the Law of Treaties, notably Articles 31–33. Some states (such as the United States) are not a parties to the treaty, but recognize that the Convention is, at least in part, merely a codification of customary international law. The rule set out in the