This is an original proceeding to review a ballot title. A prospective petition to initiate a constitutional amendment was filed with the respondent Secretary of State. The entire text of the proposed amendment is attached as Appendix A.
As a preliminary step, the Attorney General submitted a draft ballot title for the proposed amendment to the Secretary of State, which is attached as Appendix B. ORS 250.065(3). Written comments on the draft ballot title were received by the Secretary of State from two of the petitioners and two members of the public. ORS 250.067(1).1 The Attorney General considered the written comments and certified to the Secretary of State the following revised ballot title:
“CONSTITUTIONAL AMENDMENT BANNING MOST PROPERTY USE REGULATION, CHANGING ZONING RESPONSIBILITY
“QUESTION: Shall all property regulation (except by purchase) not essential to health, safety be banned; cities/counties exercise remaining zoning authority?
“EXPLANATION: Amends constitution. Bans affecting value or rights of private property owner by ‘regulation, zoning, ordinance, assessment legal strategem [sic], or police power’ by ‘any governing body, public entity, organization or person’ unless essential to public health or safety. If action would affect value or rights, property must instead be ‘taken’ by paying market value for most profitable use. Only cities and counties have any remaining zoning authority. State standards and goals become advisory only.”
The petitioners, who are also the chief petitioners of the proposed amendment, filed a petition in this court requesting that we review the above revised ballot title certified by the Attorney General. This court’s scope of review is defined in ORS 250.085(4):
“(4) The court shall review the title for substantial compliance with the requirements of ORS 250.035 and 250.039, and shall certify a title meeting this standard to the Secretary of State.”
*690ORS 250.035 sets out the form of the ballot title as follows:
“(1) The ballot title of any measure to be initiated or referred shall consist of:
“(a) A caption of not more than 10 words which identifies the subject matter of the measure;
“(b) A question of not more than 20 words which plainly states the purpose of the measure, and is phrased so that an affirmative response to the question corresponds to an affirmative vote on the measure; and
“(c) A concise and impartial statement of not more than 75 words of the chief purpose of the measure.
“ (2) The ballot title shall not resemble, so far as probably to create confusion, any title previously filed for a measure to be submitted at that election.”
The petitioners have not challenged the readability of the Attorney General’s revised ballot title under ORS 250.039.2
The petitioners contend that because they comprised a part of the measure’s drafting committee they, better than anyone else, know the “true intent and purpose” of the measure. The problem, however, is not what the drafters intended, but how to craft a ballot title which in a few words accurately informs the voter of the “subject matter” and “purpose” of the proposed measure and contains a somewhat longer statement setting out the “chief purpose” of the measure.
The petitioners argue that the ballot title certified by the Attorney General is unfair because “it will mislead the reader by focusing on a theme of stripping the government of its ability to govern” when “the purpose of the measure in fact is to enhance individual private property rights and require state leaders to protect these rights by economically compensating the owner if governmental action reduces the property value.”
*691The petitioners propose the following ballot title:
CAPTION: MAKES INDIVIDUAL’S RIGHTS IN PROPERTY INVIOLATE: PROTECTED BY THE STATE.
QUESTION: Shall property owner’s rights be inviolate; state protected; just compensation paid if property taken for public use; planning local?
EXPLANATION: Makes rights of all persons in their private property inviolate and protected by all governing bodies. Defines when taking occurs; prohibits taking without just and equitable compensation based on fair market value at highest and best use. Provides method determining fair market value. Costs of defending right borne by the takor [sic]. Requires bond for value and expenses prior to taking. Authority for planning restored to cities and counties; subject to this amendment.”
As an alternative, the petitioners support the Attorney General’s first draft, which is attached as Appendix B.
The Attorney General argues that the certified ballot title submitted to the Secretary of State meets the substantial compliance test required by ORS 250.085(4). The substantial compliance test as to ballot titles was adopted by the Oregon Legislature by 1985 Oregon Laws, chapter 447, effective September 20,1985.3
Although this court has many times4 used the term “substantial compliance,” we have never attempted to define it. Courts from other jurisdictions have attempted to define “substantial compliance” as it pertains to statutes. By the nature of the beast it can be defined in only general language. We agree with the broad definition used by the Kansas Supreme Court: “Substantial compliance requires compliance in respect to the essential matters necessary to assure every reasonable objective of the statute.” Sabatini v. Jayhawk Construction Co., Inc., 214 Kan 408, 411, 520 P2d 1230 (1974); *692see also City of Lenexa v. City of Olathe, 233 Kan 159, 164, 660 P2d 1368 (1983); Houman v. Mayor and Council of Borough of Pompton Lakes, 155 NJ Super 129, 169, 382 A2d 413 (1977). We also agree with the Washington Court of Appeals when it said: “What constitutes substantial compliance with a statute is a matter depending on the facts of each particular case.” In re Santore, 28 Wash App 319, 327, 623 P2d 702 (1981).
The revised ballot title submitted by the Attorney General does not substantially comply with the requirements of ORS 250.035. It does not correctly identify the subject matter or accurately state the chief purpose of the proposed measure. Both are essential matters which must be correctly described to assure the objective of the statute.
The major problem with the revised ballot title which the Attorney General certified is the use of the terms “banning,” “banned” and “bans.” One dictionary definition of “ban,” in the context that it is used in the ballot title, is “prohibit by legal means.” Webster’s Third New International Dictionary 169 (1971).
The use of the term “banning” in the caption of the revised ballot title does not accurately identify the subject matter of the proposed measure. The relevant part reads, “BANNING MOST PROPERTY USE REGULATION.” The measure does not ban or prohibit any property use regulation. What it in effect prohibits is the taking by the government of the value or rights of the owner of private property by zoning or regulation which is not essential to public health and safety without the payment of just compensation. The government can continue to zone or regulate a private owner’s property for purposes not essential to public health and safety, but must pay just compensation if the value of the property is reduced. The result of this measure may be that the government will find zoning and regulation too expensive and cease the practice. That is speculation. The ballot title should not include speculation as to the result or consequences of the measure. Christenson v. Paulus, 297 Or 78, 80, 682 P2d 266 (1984). The use of the term “banned” in the question and use of “bans” in the explanation of the revised ballot title are not an accurate description of the proposed measure for the same reasons.
The chief purpose of the measure proposing the *693constitutional amendment is set out in sections (2), (3), (4) and (8). See Appendix A. A paraphrase of the chief purpose is as follows:
Taking any of the value or rights of private property by regulation, zoning, ordinance, assessment legal stratagem, or police power for any purpose which is not essential to public health and safety is prohibited without just and equitable compensation based on the current fair market value of the property taken at its highest and best use at the time of taking. A taking occurs when any governing body, public entity, organization or person appreciably diminishes, damages, deprives or expropriates the rights of any owner of private property. The taking of real property shall be in fee simple. The governing body of each city and county shall have authority over all matters pertaining to planning and zoning, and state standards and goals shall be advisory.
An example demonstrates the chief purpose. If the government by passing zoning regulation reduces the value of a piece of land by 25 percent, then it is required to pay the owner the full fair market value for the fee simple title to the land.
The above paraphrase contains 124 words. The problem is to condense it to 75 words for a statement of purpose. We are also required to find 10 words which correctly identify the subject matter and 20 words for a proper question.
We certify the following ballot title:
CONSTITUTIONAL AMENDMENT REQUIRING PAYMENT FOR PROPERTY WHEN REGULATION REDUCES VALUE
QUESTION: If government regulation, except for health and safety, “appreciably” reduces property value shall owner be compensated for entire property?
STATEMENT OF PURPOSE: Amends Constitution. Taking value or rights of owner of private property by regulation, zoning, ordinance, or police power for purpose not essential to public health and safety is prohibited without just compensation for market value of property at its highest and best use. Real property taken in fee simple. Taking occurs when governing body appreciably reduces rights of private property owner. Cities and counties are responsible for planning and zoning. State standards are only advisory.
*694APPENDIX A
CONSTITUTIONAL AMENDMENT
Be It Enacted by the People of the State of Oregon:
The Constitution of the State of Oregon is amended by adding Section 41 to Article 1 as follows:
“Section 41. Individual’s rights in private property inviolate; and protected by the state.
“(1) The right of an individual to acquire and own private property and use it for any purpose; except for those uses that endanger the public health and safety; enjoy the fruits of its production; dispose or sell it at its fair market value based on the highest and best use shall be inviolate, the rights inalienable and shall be protected by the state, and the political subdivisions thereof.
“(2) Taking any of the value or rights of the owner of private property by regulation, zoning, ordinance, assessment legal strategem [sic], or police power for any purpose which is not essential to public health and safety is prohibited without just and equitable compensation, assessed and arranged prior to the taking, and such taking of real property shall be in fee simple.
“(3) A taking occurs when: Any action by any governing body, public entity, organization or person the affect of which is, or will be to appreciably diminish, damage, deprive or expropriate the rights of any owner of private property, including the right to leave property equally to heirs general.
“(4) Just and equitable compensation shall be based on the current fair market value of the property being taken at its highest and best use at the time of the taking, and it must be declared a taking and paid for as title passes.
“(5) Just and equitable compensation shall be determined by negotiation, arbitration, or jury trial in the Circuit Court with jurisdiction wherein the major portion of the property is located.
“(6) All costs incurred by the owner in determining the fair market value of any property being taken shall be borne by the initiator of the taking action.
“(7) The initiator of a taking; as plaintiff, shall post a bond adequate to cover the fair market value, as determined in Subsections (4) and (5), of the subject property and all the expenses that might be incurred by the owner in protecting his rights and interest in the property. Said bond to be *695deposited in an escrow account with a legally licensed escrow agent of the state of Oregon.
“(8) Subject to the provisions of this section the governing body of each city and county shall have authority over all matters pertaining to planning and zoning, and state standards and goals shall be advisory.
“(9) Nothing in this section is intended to prevent the owner of a property subject to a taking from bringing suit or action for relief and just and equitable compensation, plus all reasonable expenses that might be incurred.
• “(10) The legislature shall enact legislation to carry out the provisions of this amendment. This amendment shall supersede all constitutional provisions in conflict herewith.
“(11) If any section portion, clause or phrase of this amendment is for any reason held to be invalid or unconstitutional the remaining sections portions, clauses and phrases shall not be affected, and shall remain in full force and effect.
“(12) Definitions: The following words, used in this amendment (sic) shall have the following meaning as applied to this amendment unless the text otherwise requires:
“(1) INVIOLATE: Individual rights in private property inviolate or incapable of being broken, taken or destroyed, rights indestructible secure from violation, infringement, assault or trespass.
“(2) INALIENABLE; Rights to title cannot be usurped or transferred by another, incapable of being surrendered, transferred or taken, annulled, voided, undone, forfeited or taken.
“(3) FEE SIMPLE: An estate in real property which the owner has the greatest power over title possible to have under our system of law. He may dispose of it by sale, or trade or will, as he chooses. It is the best title one can have, complete ownership.”
*696APPENDIX B
CONSTITUTIONAL AMENDMENT PROTECTS PROPERTY RIGHTS TAKING PROPERTY PROHIBITED WITHOUT COMPENSATION.
QUESTION: Shall constitution require “just compensation” if government action reduces property value, with cities, counties responsible for land use planning, zoning.
EXPLANATION: Amends constitution. Prohibits taking any value or rights of private property owner by zoning, ordinance, police power or assessment for purposes not essential to public health and safety without “just compensation” based on fair market value at highest and best use. Such taking of real property must be in fee simple. Taker bears costs of determining fair market value. Cities an counties are responsible for planning and zoning. State standards and goals are advisory only.
The written comments are a part of the record on review in this court. ORS 250.067(4).
ORS 250.039 provides:
“For all measures, the Secretary of State by rule shall designate a test of readability and adopt a standard of minimum readability for a ballot title. The ballot title shall comply with the standard to the fullest extent practicable consistent with the requirements of impartiality, conciseness and accuracy.”
Senate Bill 882, sponsored by the Secretary of State, became 1985 Oregon Laws, chapter 447. Nothing in the available legislative history gives the reason for the amendment to ORS 250.085(4) adopting the “substantial compliance” test.
State v. Pottle, 296 Or 274, 677 P2d 1 (1984); Modoc Lumber Co. v. EBI Companies, 295 Or 598, 668 P2d 1225 (1983); Webb v. Highway Division, 293 Or 645, 652 P2d 783 (1982); Brown v. Portland School Dist. #1, 291 Or 77, 628 P2d 1183 (1981); Dowers Farms v. Lake County, 288 Or 669, 607 P2d 1361 (1980).