t- -r^\ ■ I .•^••■.. J.-, i^' 24579 LETTERS ON THE INTERPRETATION OK THE mi\kl COMpTITUTION (AI.I.RI) THE BRITISH NORTH AMERICA ACT, 1867 BY T. J. J. LORANOER Si ris pitffin. fiiifii In lima. SKCoX!) AND Tmi{|) F.mTKHS MONTWKAI. MKArCHKNIIN \- VAI,()IS, Muokski.i i k> \ni. I-kimirv 2."iplication of this doctrine to the juridical interpretation of tho Canadian Constitution. — II. The Constitution has a fourth source of interpretation in the jurisconsults. Motives which induced the autiior of those letters to undertake the work. — III. Utility of judicial decisions on constitutional conflicts in the interpretation of the Constitution. Dissitrtation on the msiKH*- tive jwwera of the Federal Tarlianient and of tho Ix^jfislature^ to pass tavern license laws. — IV. Text of the jud^niont rendered on the 15th of Docenilior, 1888, by the Privy Council in the case of H(Kl|^e (VI. tho (iueen.— V. Ccmclusion from the present dissertation and application of that jud<;ment. In countries governed by a. single legislative body, the authority of the law is supreme and no person can call its lawfulness in question. Such is the principle that prevails in England. Before confederation the same principle was in force in the colonies of British North America, whoro laws of the legislatures not disallowed commanded absolute obedience from the populations and exacted a rigorous execution from the tribunals. In unitary countries having a single government, questions as to the validity, or, to employ the usual term, the const Unt'mmlify of the law are unknown. It is otherwise in confedevated States, such as the Dominion of Canada, where the legislative power is divided into two parts, one of which 5 66 Letters on the interpretation of tfie [Second belongs to the central or federal government, and the other, to local or provincial governments. So it is with the executive power. . - It necessarily follows from this division of powers that the act of each legislature and of each executive raises a question UH to the competence of the body passing it to do so, and may thus create a conflict of authority between the parliament and the legislatures, the central and the local governments. Before receiving the definitive sanction of authority and being put into execution by the tribunals, the competence of the law must be subjected to three tests, each of which implies an inter- pretation of the Constitution. The first test is made by the legis- lative body itself, which is called upon to j udge of its competence and before which every bill rai.ses implicitly the preliminary question of jurisdiction. At the introduction of the bill, that body must inquire whether the Constitution gives it comi)e- tence, and to solve that question, that Constitution must be interpreted. (.)nly when the answer is favorable to the bill, does it come up for debate. To judge of its powers, the legisla- ture, therefore, makes itself the interpreter of the Constitution. The legislative power is thus the first of the constitutional interpreters. (1). The second interi>reter of the Constitution is the executive authority which, before putting the law into execution, must be convinced of its constitutional value and, in that sense, inter- pret the (Constitution. Tt is true that, according to the usage of responsible government, the ministers who advised the (1) The r<}/(' of iiitori)rotor of tho Constitution thus attributed to legis- latures, to executive govoruuients and to tribunals is adopted froai.Iudgo Story, on the American Constitution, n. 87H et neq. Letter.] Federal ConsiUutiun. '- ' ► W sanction of the law cannot oppose its execution, and tliat the second question of interpretation is solved by the first and con- founded with it. It is, however, no less true that, in the abstract theory of powers, the legislative body and the executive author- ity are distinct, forming two separate branches of the public domain, and that, for the execution of any law, the latter must be satisfied, by the interpretation of the Constitution, that the former was competent to pass it. It may, moreover, hapi)en that the mode adopted by the executive for putting a law into operation is not warranted by the Constitution. Just as the question of competence to pass a law comes up in the legislative body, so before any particular mode for its execution is adopted, the question of competence of that mode must come before the executive council. And here again it is l)y the interpretation of the Constitution that a solution is found. But the law, thus .sanctioned and (enforced, has not yet received that definitive and final sanction which securer it from contestation. To be put in force by the tribunals, the latter must be satisfied as to its constitutionality, that is, as to the competence of the legislative power to j:>as8 it, and the mode employed by the executive power to put it into execution. If one or other, or both of these qualifications be lacking, the tri- bunals must not carry the law to execution. And since it is on the interpretation of the Constitution that they rest their deci- sion, it follows that thejudicial body is the third interpreter. Thus it is evident that the Constitution has necessarily three public and authentic interpreters. But. though they all possess the same character, they are not invested with equal authority. It is the judiciary that judges ultimately as to the soundness 68 letters on the interpretation of the [Second of the interpretation put by the others, and pronources defini- tively on the constitutionality of their uct8. The nature of fede- ral rule, which is a rule of contention and conflict of authority, of poasible encroachment by one legislative body on the domain of the other, — nece.ssary result of obscurity in the contitutions themselves, of difliculties in interpreting them and often of l)olitical ambition and passions, — makes it clear, therefore, that there must be a sovereign tribunal or arbiter, invested with authority to judge these questions in the last resort, and inves- ted with the task of eliciting from the Constitution its true meaning and of interpreting it with supreme and definitive authority. Now where shall we find this final arbiter and judge of the Constitution, if not in the judiciary ? In principle it matters little whether that power be exercised by a tribunal clothed with special authority to judge constitu- tional cases, or by the ordinary tribunals. The mode of appli- cation is of little consequence. In some federations it is upon such special tribunals that the duty of deciding constitutional questions devolves. Such was the case with the (Jerman C/onfederation which came to an end in 1866, and the same usage is in force in the Swiss Confederacy of the present day. In confederate states which have no such special tribunals, or in those where the law is silent on that point, that duty, with the other judicial attributes, is incumbent on the common law tribunals. In the United States of America, the Supreme Court judges, in last resort, questions of constitutional law which, however, are first taken before the inferior federal or State tribunals. These questions are not, nevertheless, tlie main object of the suit, inasmuch as there is no special court to which an origi- letter.] Federal OnistiUition. 69. nary recourse may be had to declare unconstitutional a law of CongresH or of any of the States. It is, generally speaking, only incidentally and in the course ofa suit that, on the objection of one or other of the parties, the question is raised as to the cons- titutionality of the law invoked by either of the two, or as to the conflict between a State law and the law of Congress or vice vend. The same rule holds in the provinces of the Canadian Confederation, and especially in the province of Quebec. At first sight, wc might wonder at the silence of the consti- tution on this pjint. The authors of Confederation might) one would think, have expected such conflicts between the two legislative l)odies and have provided a special plan for their settlement. There is, nevertheless, nothing in the resolutions of the Quebec Conference, or in the Constitution, which denotes any such anticipation. The only arrangement that has refer- ence to the tribunals is that which is found in clause 101, which enacts "thut whenever occasion shall ref power, for these are decided not by the laws of Canada but by the constitution itself. It is true that constitutional ([UPstions may bo brought before the Supreme ('ourt of Canada, but that is in virtue of its general nppellateattributes in causes within its competence, and not on any ground of privilege. Tf the causes in which these •lucstions are raised are such as would come before the Supreme ('ourt in its appellate jurisdiction, that is, if in the province of Quebec, the suit amounts to two thousand dollars, if it is a case brought before the Exchequer Court, if it is a marnhmvn, a habeas corpim, or a (luestion of municipal by-law, that tribunal will take ctignizance of it. But in other coses, tliey will stop within the jurisdiction pertinent to the cause in whicli they are an incident, just as every other accessory follows the course of its principal. The legal theory on which the jurisdiction of tribunals on the constitutionality of the laws is based, is the following: Every law that is unconstitutional, for want of authority in the body that passed it, is null, irreparably and absolutely void. Tt is a nonentity, p?'o nihilo hahetur. Tt is the same with unconstitu- tional acts of the executive power, and whenever the judiciary is called upon to take cognizance of one or the other, its duty is — not to annul them — what has no existence cannot be annulled — but to declare them null and non-exi.stent. The first condition of a judicial recourse is that it be founded on a law in force. As we have seen, in the absence of a special tribunal or of a pro- cedure organized for denouncing these nullities to the ordinary tribunals by demande principale, they are invoked during the suit I^ter.] Federal (hmtUtUion. ' It*^ by tho advorao party opposed to that whioh founds its claim on the law or act clttiined to he null. If an action or prosecution before a civil or mixed triltunal, is based on a law or act tainted with unconstitutionality, the defence, in denouncinp that un- constitutionality, and inclniniing thai tliPsuit should bedecided without regard to that unconstitutional law or act, obtains the dismissal of the suit, without even being bound to put on spe- cial conclusions to thateffect. If such unconstitutional law or act is invoked by the defendant, the plaintinhas the same right in reply, and so on through all the stages of the case. All judges, Avhatever be their competence, civil, criminal or mixed, or whatever be their rank in the judicial hierarchy, from the com- missioner of the lowest courts and the justice of the ytence to the judge of the Queen's Bench, have like jmwcr to reject an unconstitutional law and to take no account of it. Tf the princi- pal cause in which the difficulty arises is appealable or suscep- tible of recourse to a higher court by ccrtwrari, the constitu- tional question raised follows the same rule ; but it does so not by virtue of a special privilege, but by virtue of the appeal- able or evocable character of the main cause. Tf that main cause be neither appealable nor evocable, the judgment of tho inferior tribunal on the incidental point will also be final. On the other hand, the want of appeal from one court to ano- ther is not irreparable, since, definitively every colonial case can be brought before the Privy Council, by virtue of the pre- rogative of the Sovereign to revise every judgment rendererojUem,ui\ mjumn af> inifpio scparnnten ; lici- tnm ah iUicito discei'vcntes.'] Modern jurisconsults do not pretend to this excellence, hut they have not abandoned the right any more than they shrink from the duty — right and duty consecrated by ten centuries of noble traditions and of devotion to legal science — of ofi'ering the help of their studies and the tribute of their lucubrations to the interpretation of the laws whenever the public welfare claims them at their hands. Now, has an occasion at once more favorable and more urgent ever presented itself to the juris- consults of Canada, of proving their zeal for the sacerdotium spoken of by the Roman jurisconsult and their devotion to the (*) It is probablp tliat the answers of tlie jurisi'oiisults had the author- ity of law under Valentinian II 1, inasmuch as he ('ontirnied the wri- tings of Uaius, of Illpiin.of TauhiN, of I'ajHuian and otliers; and forbade the judfjes to dissent in <|ueKtion« of law from the opinion of those writers. To ol)viate the inconvenience that niijrht arise from diversity of opinion, on the same question, lie r>niered tliat in sucli a case, the judjies should defer to the majority ami, if the division were eijual, that the opinion of Papinian should prevail. — Ferridre: Iflftoiri : 77 III. UTIMTY OF JUDICIAL HECISIONS ON CONSTITUTIONAI- CONFLICTS IN THE INTERPRETATION OF THE CONSTITUTION. DISCU&SION OF THE RESPECTIVE POWERS OF THE FEDERAL PARLIAMENT AND THE LEGISLATURES TO PASS TAVERN LICENSE LAWS. As in this interpretation of the Constitution, which should come to pass in the same manner as the ordinary interpreta- tion of other laAvs, that is, by the exposition of doctrine and the discussion of precedents, the conflicts raised between the legislative bodies themselves and between them and the tri1)U- nals, must occupy a large place ; and, as in order to invest them with actuality, the problems raised should be solved just Avhen they present themselves, such questions deserve some attention in these Letters, even at the risk of interrupting their didactic order. Thus, the discussion of the conflict raised between the provin- cial license law and the law passed on the same subject by the federal parliament (where a bill for its abrogation was only lately introduced), — a law of which I have maintained else where the unconstitutionality — will supersede in the present Letter the discussion commenced in the preceding one. It is by the application of the rules there set up for assigning to the federal parliament and the legislature their respective attri- butes of jurisdiction, that this conflict must be terminated. The jurisdiction of parliament embraces matters of common interest to the entire Dominion ; that of the legislatures extends only to matters of special interest to each of the pro- vinces. The powers of the two bodies are e(iually divided into 78 Letters on the iiUerpretaiion of the [Second two categories: powers specially or exclusively assigned to each of them by articles 91 and 92, and general powers assigned to parliament by the leading clause of the first of these articles and to the provinces by paragraph sixteen of the latter. There are only four classes of subjects on which parliament and the provinces have concurrent power of legislation, in certain cir- cumstances : direct taxation, agriculture, immigration and public works. In all other cases the powers are mutually exclusive. This last inference is drawn from the restric- tive language of article 91, which says: "The exclusive legislative authority of the parliament of Canada extends to all matters coming within the classes of subjects hereinafter enumerated," and from the equally restrictive language of article 92, to the effect that " in each province the legislature may exclusively make laws in relation to matters coming within the classes of subjects next hereinafter enumerated." The power to grant tavern licenses and to make them the object of a law cannot at the same time belong to the Parlia- ment and to the legislatures, and as whichever of the two bodies it is as.signed to excludes the other, one or other of the two laws, that of the Dominion or that of the province of Quebec, is unconstitutional and ultra vires. Since article 92 says that the legislature of each province may exclusively make laws relative to " shop, saloon, tavern, auctioneer and other licenses," it is evident that this power, as proved by the text itself, belongs to the provinces only, and to the exclusion of parliament. The federalists, who in vain deny this power, elude its application by a sophism. They say : supposing that the pro- vinces had the power to pass laws relating to licenses, the ninth Letter.] Federal (hmtUution. ■-, . 79 ^ paragraph of article 92, which recognizes that they have such power, restricts them to raising a revenue for provincial, local or municipal objects. Therefore, they have not tho power to regulate licenses, that is, to determine to what persons, on what conditions and with what formalities, they shall be granted, and to provide for the discipline of liquor saloons, &c. And they urge as this second power has not been granted to the provinces, it pertains to the parliament, in virtue of the prin- ciple (which I not only do not reject, but which I have upheld as one of my maxims of interpretation) that all legislative power not recognized in the Provincial Legislatures belongs to Parliament. We shall see later on . dw, in addition to this pretention, they contend that this license legislation is taken away from the provinces, because it atfects commerce, which is a subject exclusively within the jurisdiction of Parliament, and also how this second argument, which is no more conclusive than the tirst, may be refuted. Let us first consider the former contention. As in private concerns, the stipulation of a riglit implies the obligation on the part of the debtor to allow the benefit of it to the creditor, and the power of the latter to adopt means necessa- ry to secure its exercise, so, in public law, a power granted to a nation by a constitution or a treaty implies the faculty of em- ploying all necessary and suitable agents to ensure its exercise. These necessary agents, which as accessories follow the princi- pal, constitute implicit powers, the action of which is a conse- •luence of the concession of the explicit power and is confounded with it. The right of building on the ground of other persons comprises that of transporting thither and putting in order the 80 Lettei'a (TXthehUerprelaXvj.v ojthc , '>•' [Second materials for the purpose ; aud the power of declaring war, recognized by a constitution, comprises that of carrying it on successfully, of enrolling armiet;, of procuring munitioas and of levying sufficient taxes for theso objects. On this correlation of principal and accessory pOAvers, is based the doctrine of powers express or explicit and of powers presumed or implicit, the former of which comprise the second and to them impart vitality. Let us see how this doctrine, applied to the power of the provinces to make license laws, has invested them with the right of regulating their grant and operation. The sale of intox- icating li(iuors being in its nature dangerous to good order and to the public weal, it is the duty of the State which permits it to licensed persons and forbids it to the others to surround the license with precautions likely to diminish these dangers and to protect public morality. The formalities im- posed as to the granting of licenses, their number, the selec- tion of persons to whom they are granted, the locality in which the licence is to have force, the suitableness of the house in which the sale is carried on and the maintenance of order therein, are among those necessary precautions. The persons \Mho obtain licenses should be persons of correct morals. The taverns or inns ought not to be too numerous or too near to each other. The houses ought to be respectable and suitably furnished. Order must be maintained and no sale of liquor must take place in the night time, on Sundays, on holi- days or day.s when riot or disorder is likely to break out. These are conditions the enforcement of which is necessary to attain the ends of the law authorizing the raising of reve- nue for provincial, local or municipal objects — without injury Letter.] ; Federal Constitution. 81 to public morals — which form the subject of the regulations whose exercise is by some refused to the provinces. But is it not evident that, by virtue of the maxim above cited, to the intent that, in the application of a power, all the ordina- nary and proper means for i)Utting it in action are deemed to form an integral part of it, this regulation is in germ in para- graph 9 of article 02, and is derived from it as logically as if that paragraph had specially granted to the provinces the faculty of enacting it ? Qui vcut la Jin veut les moyens, is a say- ing the good sense of which, apart from any speculative prin- ciples, would justify this interpretation. As for the power of sanctioning the license law by the impo- sition of penalties on those who infringed its provisions, if it were not implied by virtue of the principle that authority to enforce his law is a riglit inherent in the legislator, it would be found in the fifteenth paragraph of article 92 which enacts that "the imposition of punishment by fine, penalty, or impri- sonment for enforcing any law of the province made in relation to any matter coming within any of the classes of subjects enumerated in this section (that is article 92.) is within the jurisdiction of the legislatures." To complete the demonstration that the power of regulating the grant and operation of licences for the sale of liciuors is inherent in the power to impose them, we need only imagine a license law without such a provision. Would not such a law, restricted to the mere granting of licenses and the imposition « of the tax, without any reference to the (qualifications of the persons licensed, the conditions on which the license should be granted and the manner in which the sale of liquors .should 6 82 ' Letters on the iiitfrpretntion of the ' [Second bo conducted, remain a d^ad letter, and would not the provi- sion of the federal constitution which invests the provinces with the powers of passing it, become illusory ? But we cannot imagine a legislator so regardless of common sense ! The folly of such an arrangement which would deprive the law of ail its force, would be undisputed. But even, wore it so, the maxim which dominates all legal interpretation, viagis rnlcnt «piam percat, would eventually impart life and sense to it ; and that sense, favoured by that other maxim of Roman law : Ottijurudictw (by the term jurisdidio all public pow'er, legisla- tive !ind judicial being designated) data est ea (juoque conccssa esse mdentur, sine quihus jurisdictio erplicari non potuit, would be the one which weare defending, namely : that to the jurisdiction accorded to the Provincial legislatures as to liquor licenses and the authority to grant them, is added by implication and as the only means of putting the law into execution, the power of regulating them. To this absolute and final conclusion, the partisans of federal competence in this matter, will reply, perhaps, — and it is the only answer which they can make — that the federal constitu- tion, if it has endowed the provinces with the licensing i)ower, has partitioned the legislative autliority on that point, having invested the Legislatures with the power of granting licenses to raise a local revenue, and the Federal Parliament with the power of regulation. This latter power, they may argue, not having been granted to the provinces, belongs the Federal Parlismient, not only implicitly, as Ave have seen, but also explicitly by virtue of article 91, which clothes it witli the power " to make laws for the peace, order and good govern- ment of Canada, in relation to all matters not coming within liOtter-l - Federal Chnstittition. ' . 83 the classes of subjects by tliis act assigned exclusively to tlie legislatures of the provinces." Tliere are many objections to be made to this reply. The chief one is that the power of general legislation for the peace, order and good government of Canada, refers only to cases of common interest to the whole Dominion and of general application, and that the peace, order and good government of the provinces fall within the jurisdiction of each of them hi particular, as being matters of municipal police, on wliich the legislation of one province must differ essentially from that of another ; l)ut, regarded from the stand point of its intrinsic value, and of the collaboration which it lends to the two legislative bodies on the same question, the least that can be said of this pretention is, that it lacks likeli- hood. In fact, the two legislative bodies, organized separately as complete and independent legislatures, may well naturally aid each other. One of them may pass a law to give a more effective sanction to the law of the other and extend its appli- cation. A federal law may make it a crime to contravene a local law and, on the other hand, a local law may attach a civil sanction to a criminal laAV. This reciprocity of good offices on the part of the legislatures is within the spirit o? the consti- tution, and^llows and favours the ends it has in view. But between the execution by the extension by an alien legislature of a law perfect in itself and the perfecting of an incomplete law, between the concurrence of two bodies to favour, within the limits of their respective spheres, the execution of a law passed by one of them (for example, the federal law voting a salary to an additional judge appointed by the legislature), and the V:.;^'- 84 Letters on the interpretati-%1 Constitution. 05 " impose fines for their violation and imprisonment in default " of payment. " The appeal was heard by Chief Justice Spragg and judges "Patterson and Morrison, who reversed the judgment of the " Court of Queen's Bench, thus confirming the conviction. The " Appeal Court taking for granted the constitutionality of the " Ontario law, consequently decided that the i)rovinciallegisla- " ture had and alone had the power to pass laws for the imposi- " tionof penalties or imprisonment for the violation of aprovin- " cial law in relation to a matter falling within the class of " subjects over which the provinces alone had jurisdiction, and " that their legislatures had the right to delegate their authority " as the Legislature of Ontario had done in the present instance. '' On appeal to this tribunal against the judgment of the " Court of Appeals, Mr. Kerr, Q. C, and Mr. Jeune, intimated to " their lordships, in their able arguments, that the first and " main point in the case is whether the fourth and fifth sections " of the license act of Ontario, 1877, passed l)y tlie Ontario " legislature, was uHra rivet, abiding tliat the point in question, " being raised between the Parliament of the Dominion and " the Provincial Legislature was a matter of importance. " Their lordships do not think it necessary, in this case, to " lay down any genei'al rule for the interpretation of the " British North America Act. The remark of Chief Justice " Hagarty, that in all those questions of the unconstitutionali- " ty of laws by reason of exceeding powers, the wisest course " is not to enlarge the field of discussioi:i by entering into con- " siderations not absolutely raised by the question in dispute " is a just one. They do not lose sight of the fact that in a •^iH •'.■;■•'• 96 Letters on the interpretation of the [Second prectdinp case arising out of the same statute (Parsons vs. The Citizen's Company), their Lordships advised those to whom the difficult task of deciding tliose questions belonged, to judge each case as far as possible on its own merits, without engaging in broader interpretations of the statute than the decision of the case demanded. " The appellants have maintained that the Legislature of Ontario was without competence to restrict the traffic in spirituous liquors, that this competence ])ertains entirely to the Parliament of the Dominion, and has been withdrawn from the provinces l)y the British North American Act (18G7) by virtue of section 91. The paragrai)li of that section which they hold to have been infringed by the Liquor License Law is paragraph 2 : " the regulation of trade and commerce", and the decision in the case Russell vs. Regina has been invoked in support of the principle that the entire legislation on the sale of liquors Avas conferred on the Domi- nion Parliament and taken from the Provincial Legislatures. It appears, however, to their lordships that the decision ren- dered by the tribunal in that case has not the effect supposed, and thai when jyi'opcrly considered^ it should he taken rather as an authority in svpport of the judgment (f tlie Court (f Appeals. " The sole question there was, whether it was competent to the Dominion Parliament, under its general powers, to make laws for the peace, order, and good government of the Domi- nion, to pass the Canada Temperance Act, 1878, which was intended to be applica1)le to the several Provinces of tlie Dominion, or to such partsof the Provinces as should locally adopt it. Tt was not doubted that the Dominion Parliament had such authority under sec. 91, unless the subject fell Letter.] Federal Conatitutbn. 97 "within some one or more of the classes of subjects whicli by " sec. 92 were assigned exclusively to the legislatures of the " Provinces. "It was in that case contended that the subject of the Tcm- " perance Act properly belonged to No. 13 of sec. 92, " Property " and Civil Rights in the Province," which it was said belonged " exclusively to the Provincial Legislatures, and it was on what " seems to be a misapplication of some of the reasons of this " Board in observing on thai contention that the appellant's "counsel jmncipally relied. These observations should be "interpreted according to the subject matter to which they " were intended to apply. " Their Lordships, in that case, after comparing the Tem- " perance Act with laws relating to the sale of poisons, observe "that:— "//««!8 of this nature dcsigiicd for the p'rnmotion 1J4^ Letters on the interpretation of the ' [Third account of the false interpretation given to the judgment of the Privy Council rendered in the Russell case, by which judgment the last law had been prompted. The falseness of that interpretation, according to the author of the repeal bill, had been recognized by a judgment subsequent to the license law, rendered by the same tribunal, the judgment in the Hodge case. This appreciation of the two judgments was shared in by a good many members. On the other hand, a section of the House maintained that the judgment in the Hodge case was not susceptible of the application attributed to it; that it had neither shown the false interpretation put by Parliament on the judgment in the Russell case, nor proved the unconstitutionality of the license law. The real question, therefore, had to do with the nature of the decision of the Privy Council as to the constitutionality of this latter law, some holding that the supreme tribunal had tentious in it, it requires no oxamiuatlon and the parties interested submit to it voluntarily. Oontentiom jurisdiction is that which is exercised against a party who is obliged to submit to it, whose condemnation is sought, who must be in which there is a trial — in other words, which brings on a suit. According to this distinction, the reference of a constitutional or legal question by the Federal Government to the Supreme Court, or by the Queeu in Council to the Judicial Committee, is a matter of volmitary or gracious jurisdiction, and this same reference made to tribunals in a suit is made in contentious jurisdiction. We will also call (he former direct reference Mid the latter indirect, because, in the one case the opinion of the ^Supreme Court is the chief and direct object of the reference ; in the other the judgment of the tribunal on the question is brought out incidentally in the course of the suit and the reference or submission of this question is indirect, with regard to the suit in which it occurs. Letter.] Federal Constitution. 116 pronounced it invalid, while others affirmed the contrary. When the House ordered the reference on the constitutionality of that law, it must have looked for a decision like that ren- dered by the Privy Council in the Russell and Hodge cases, on the very point expressly raised in the case submitted, and on which the tribunal would be forced to pronounce expressly, so as to judge it, no longer by implication, but explicitly. V. THIS CLAUSE 52 RELATES TO ADMINISTRATIVE AND EXECUTIVE MATTERS. To have its full effect, which is to direct the action of the Federal Parliament as to the repeal or maintenance of the law, and that of the Legislatures, on the subject, and serve as a precedent to the tribunals, this decision should, therefore, have the same character of contentious juridicitj'' as the two decisions afore-cited, and be in the legal conditions requisite to create la chose jugh, that is, be rendered in a contradictory suit between legitimate parties. Now, is it necessary to say that the report made by the Supreme Court by virtue of section 52 of the Supreme Court Act above cited, on demand made by the Governor in Council, that is by the Federal Executive, would have none of these juridical conditions? That report would not be made in a suit undertaken between legitimate parties and would be in no wise obligatory. According to the Supreme Court Act and the English practice, of which we are about to speak, such a report is demanded voluntarily and made ex parte, for the iuibrmation of the executive and the 116 Letters on the interpretation of th3 [Third guidance of its administrative action. It could not, especially, exercise any influence on the action of the Federal Legislature which is not even vested with the power to ask for it, and to which section 52 does not extend (1). Created for the needs of the administrative service, this reference cannot pass the domain of the latter. ''' " In the juridical usages of England, clause 52 does not, more- over, constitute a novel practice. It is borrowed from the Impe- rial Statute 3 and 4 Guil. 4, c. 41, entitled : " An Act for the better administration of justice in His Majesty's Privy Council," clause 6 of which is to this effect : "It shall be lawful for His Majesty to refer to the said Judicial Committee forbearing or consideration any such other matters whatsoever as His Majesty shall think fit, and such committee shall hear or con- sider the same, and shall advise His Majesty thereon in manner aforesaid." There can be no doubt that, in its application as in its con- text, the effect of this clause is restricted to the administrative jurisdiction of the Executive Government of England and that it was not intended for legislative purposes. In fact, the Execu- tive Government is without control over the legislative domain, and it is not in the power of the sovereigns to refer a legisla- tive question to any body politic whatever, any more than to the tribunals of the empire, otherwise than in the ordinary juridical form, and in the same way as any other party having (1) We shall see later on in what circnmstances and on what condi- tions, British legislative bodies may ask for the opinion of judges on special questions of law, and the effect of that opinion. *•■■,- Letter.] Federal Constitution. / 117 recourse to the judicial authority. Setting aside the eminence of the tribunal and the special character ofthe argument, which is made by the parties as in an ordinary suit, this administrative reference is in its nature and effects assimilable to the refer- ences made by the Crown to its law officers. VI PROOF OP THIS PROPOSITION BY SEVERAL ENGLISH PRECEDENTS AS TO REFERENCE TO THE PRIVY COUNCIL, WHICH REFERENCE DICTATED OUR CLAUSE 62. INTERPRETATION OF CLAUSE 4 GUIL. 4, C. 41, AUTHORIZING A LIKE REFERENCE BY THE SOVEREIGN TO THE JUDICIAL COUNCIL. The following cases referred by the Crown to the Judicial Committee by virtue of clause 4 of Guil. 4, c. 41, above cited, may give an idea of the nature of the subjects which are thus dealt with. " When a public functionary has been suspended, the matter is generally referred by the Crown to the Judicial Committee on the recommendation of the Secretary of State, although not invariably, for in certain cases the latter takes upon himself the responsability of advising the Crown to confirm or reject the suspension." (22 Geo. 3, c. 75. Ex parte Robertson 11 Moo. P.C.C. 258.) "The Judicial Committee has also, on the special reference of the Crown, made through the Secretary of State, heard a case based on a memorial presented to Her Majesty by the representatives ofthe Island of Grenada, asking for the dismis- 118 Letters on the interpretation of the [Third sal of the chief justice for bad conduct, and a counter-memorial from that functionary." (Representatives of Grenada, 6 Moo. P. C. C. 38.— The parties were heard by counsel before the Judicial CJommittee. The case of judge Elz6ar Bedard, also heard by Judicial Committee, on special reference of the Crown, is particularly interesting. Judge Bedard had been, since 1836, a judge of the Court of King's Bench for the District of Quebec. Transferred in 1848 to Montreal, as judge of the same court, for the latter district, he wished, at the opening of the succeeding term, to take his rank on the bench according to seniority and claimed pre- cedence over judges Day and Smith, who had been appointed after him, but who were his seniors in the District of Montreal. The latter protested against his pretention, notwithstanding that the Commission appointing him judge for the latter dis- trict had accorded him that precedence. The four judges, namely, Chief Justice Rolland and the three other judges who have just been mentioned, having deliberated on the matter, the majority, that is. Chief Justice Rolland and judges Day and Smith, decided against judge BMard and gave their deci- sion in the form of an order, bearing date July 1st, 1848, and entered at that date in the records of the court. Judge BMard appealed against this order, by a petition addressed to the Queen who referred the point in dispute to the Judicial Com- mittee. The Attorney-General and Sollicitor-General intervened in the case and were heard on the petition, in support of which they pleaded. The judges who had delivered the order also sent a Letter.] Federal CkmstiM/Um. 119 petition sustaining their opinion but were not heard by Coun- sel before the Judicial Committee, who made a report favora- ble to judge B4dard and hostile to the order against which he had appealed, and the report was confirmed by order in Coun- cil. {In re B^dard, 7 Moo. P. C. C. 23). A person who thought he had a right to be admitted as an advocate in the Royal Court of Jersey, presented a petition to the Queen in Council, asking for the issue of an order to the bailiff of the island, enjoining him to admit the petitioner to take the oath as an advocate and to practice before the Court. The petition was referred to the Judicial Committee and made known to the bailiff who produced his reply, and the two parties were heard by Counsel before the Judicial Com- mittee who refused to entertain the conclusions of the petition. (D'AUain v. LeBreton, 11 Moo. P. C. C. 64). A Frenchman, by name Adam, having been banished from the island of Mauritius by the Governor of the colony, referred his complaint to the Secretary of State for the Colonie8,and,with the concurrence of the Government, this complaint was sub- mitted to the King on Council and referred to the Judicial Committee for exa mination as to (1) the status of the petitioner ; (2) as to whether the juridical rights inherent in that Status had been infringed by expulsion from the colony. It is to be noted that it was only on these two points of law, and not to lay before the Judicial Committee the question of justice or competency in the Governor, or the question of com- 120 Letters on the interpretation of the Third pensation due the petitioner, in case he should be shown to have been illegally expelled, that the reference was made. The opinion of the Committee on both points was favorable to the petitioner. (460 In re Adam, 1 Moo. P. C. C). A number of the inhabitants of the island of Cape Breton petitioned the Crown for the restoration of the Constitution which had been granted to them in 1784, and the rescission of their annexation to the Province of Nova-Scotia which had been eflfected in 1820. The petition was based in part on legal arguments, and in part supported by reasons of policy. It was referred to the Judicial Committee with instruction to limit the hearing to law questions and to avoid all political discussion. Notice was also given of the reference of the petition to the House of Assembly and to the Legislative Council of Nova Scotia and they were authorized, if they deemed fit, to be represented by Council in opposing it. They did so and after hearing of the law officers of the Crown, of the people of Cape Breton and of the legisl^ure of Nova-Scotia, the committee made a report unfavorable to the petition. (In re Island of Cape Breton, 6 Moo. P. C. C. 259). Two colonies having entered into difficulties with each other on account of an extent of territory that was in dispute be- tween them, their respective governors agreed, with the consent of their councils, to submit the matter to the Queen in Coun- cil. After having proceeded with their evidence by means of a Letter.] Federal ComtUviion. 121 joint commission and having transmitted it to the imperial authorities, each governor presented his petition soliciting the royal decision, and this was delivered on the report of the Judi- cial Committee, to which the dispute had been referred. (Case of Pental Island, O. C. January, 1872.) The seven precedents which we have just cited show that it is only in the exercise of the executive power and on q\ies- tions of law, that the Queen in Council consults the Judicial Committee and that the application of clause 4 of Guil. 4, c. 41, is limited to these matters. The Crown does not refer to the committee even petitions for the exercise of the royal prerogative of pardon, although such petition may be submitted to it to obtain its opinion on some point of law raised by the petition. (The Queba vs. Eduljee Pyramjee, 5 Moo. P. C. C. 276.) This clause, strictly speaking, was not even necessary to authorize the reference which it sanctions, since, before the reorganization of the Privy Council and the creation of the Judicial Committee, reference of questions of law to the tribu- nals was a frequent usage. It is a maxim of common law, according to Sir Edward Coke, as cited by the authors who have written upon the royal prerogative, and especially by Blackstone and Chitty, that *' a council belonging to the King are his judges in law matters." (1 Ins. 110 — 1 Bla. 229, Chitty Prerogatives of the Crown, ch. 27, p. 409.) It was only, therefore, to regulate the application of that maxim to the Judicial Committee that the clause in question '■;,:« ;,. _v;.V , ■' ■ y i; ■ . 122 LeUers on the interpretation of the [Third was introduced. Besides, the members of the Judicial Commit- tee who were not privy councillors before, become so by their nomination. VII. THE REFERENCE OF CLAUSE 52 OP THE ACT OF THE SUPREME COURT LAW CANNOT HAVE A WIDER APPLICATION THAN THE REFER ENCE OP CLAUSE 4 GUIL. 4, C. 41, PROM WHICH IT IS BORROWED 4 DIRECT REFERENCE TO THE PRIVY COUNCIL IS NOT AUTHO- RIZED BY THE CONSTITUTION, DEVELOPMENT. The reference made by the Government of Canada to the Supreme Court not having more effect than that made by the Crown to the Privy Council, from which it is borrowed, it follows that it cannot have more extension ; that it must be limited to executive and administrative matters, and cannot be applied to those that are within the jurisdiction of the legis- lature, any more than to questions that arise as to the compe- tence of the Federal and Provincial Legislatures, and which relate to the extent of their respective powers, that is, to consti- tutional questions. The resolution of the House of Commons also mentions the Privy Council as a tribunal to which the question may be referred instead of the Supreme Court or conjointly with it. Is such reference authorized by the laws of the Empire or by the Federal Constitution? By the former it is not so expressly and there is nothing in the Federal Constitution that could directly or indirectly furnish a pretext for it. We maintain that there is nothing in the laws of the Empire *!• letter.] Federal ComtUution. 123 relative to the colonies which, beyond appeals, authorizes the reference to the Privy Council of questions arising as to the extent of the powers of their legislatures ; but, possibly, it is so authorized by implication through the practice of the Judicial Committee. The jurisdiction of that committee is mainly an appellate jurisdiction* but it possesses also a jurisdiction of first instance or an original jurisdiction. The reference of the question by way of appeal to that tribunal has been already adverted to and perhaps, we shall revert to it later on. At present the question is whether it is not of its competence as a tribunal of first instance, that is to say, whether the Federal Parliament or the Legislatures may not carry directly thither their conflicts as to their respective jurisdictions. We must, therefore, inquire what this original jurisdiction or jurisdiction of first instance is, and in what cases it is exer- cised. The authors who have written on the subject assert that it takes place by virtue of statutory or common law, and that it is exercised in two cases. The first of these cases relates to causes concerning the confirmation and extension of patents for new inventions, in accordance with 5 and 6 Guil. 4, c. 83, passed in 1835, and which created this jurisdiction; the second is thus defined by a modern author in a work on the subject, who has borrowed his opinion from Blackstone: " The subject of the following pages is the form and manner in which the Queen in Council practically exercises her jurisdiction in appeal and her original jurisdiction founded upon the principles of feodal sovereign- ty, in the case of dispute between two provinces out of the realm, or of any rights claimed under i. 'Ms from the Crown. (Macpherson, Practice of the Judicial Committee. Introduction,page X.) 124 Letters on the interpretation of the [Third Wheneoer also a question arises between two provinces in America or elsewhere as concerning the extent of their charters and the like, the King in his Council exercises original jurisdiction therein upon the principles of feudal sovereignty. And so likewise when any person claims an island or a province in the nature of a feudal principality, hy grant from the King or his ancestors, tJte determinaiion of that right belongs to His Majesty in Council : as was the case of the Earl of Derby with regard to the Isle of Man in the reign of Queen Eliza- beth, and the Earl of Cardigan and others as representatives of the Duke of Montague with relation to the Island of St. VincerU in 1764. (1 Bla., 131 Com. 426.) The application of this opinion of the prince of English juris- consults, which is found to be supported by no other precedent than the island of Pental above cited, seems at first sight rather obscure. Nevertheless, the nature of this precedent compared with the text and with the development that the author has made of it leaves hardly any doubt that by " the extent of their charter ", the author meant the territorial extent, that is, the territorial extent of the charters of provinces and not the extent of their legislative powers. Every one knows that in 1765, which is the year of the publication of the first volume of Black- stone's commentaries which comprises this opinion, there were between the British colonies in America and especially those of New England, numerous conflicts relative to their territorial limits, and it was quite natural that those conflicts should be referred to the British Privy Council. Two other reasons, fur- nished by the author himself, agree with this interpretation. The first is drawn from the very nature of the question sub- mitted to the jurisdiction of the Council, consisting of a dispute between two American provinces, which dispute could have no Letter.] Federal QmstitiUion. 125 reference to conflicts of legislative jurisdiction at that time, since each legislature was independent of the others and that in the unitary governments to which the English provinces were then subjected, such conflicts were impossible. The second reason is deduced from the title attributed to the King in taking cognizance of the dispute, namely his title to the feudal sovereignty, or, in other words, his title of suzerain or dominant lord of the fief. In feudal law, the principles or, at least, the fictions of which are still in usage in England, there is the following provision : that the King is universal lord and primary proprietor of all the lands of the Kingdom, and that no person possesses any portion of them which does not proceed from him as a gift and at the charge of military ser- vice. Thence arises the right of the British Sovereign to pro- nounce judgment as to disputes arising between provinces touching the extent of the territories covered by their charters as well as questions regarding the ownership of fiefs. It was this principle which directed the reference in the matter of the Island of Pental, and the decision rendered by the King in Council in the cases of the Earls of Derby and Cardigan, cited by Blackstone. In the third place it is impossible to suppose that in enacting the reference, the House should have meant to do so in a case not recognized by law, and that, on the other hand, it should have wished to efiect an abdication of sovereignty and to aban- don to the British Privy Council a decision which is one of its grandest constitutional privileges, that of making its own laws ; that, in order to elude an embarrassing question the members for the provinces to the Federal Parliament, those for Quebec 126 Letters on the interpretation of the [Third especially, should, in a moment of deplorable forgetfulness, have sacrificed the fruit of labours which had engaged their fathers for generations, that of self-government, and, for a transitory interest, have made shipwreck of a liberty so dearly won! This language, however severe it may be, would be more than justified by the event, if those who voted the reference, had meant to make it direct and not rather await the ordinary and contentious action of the tribunals, to model their legisla- tive conduct upon the decisions thus rendered I We have seen how reference is made by the Federal Govern- ment to the Supreme Court whose opinion is sollicited, and that this opinion, not obligatory for the Government, is still less so for the legislature. Of that reference to the Supreme Court it may be said, as has already been said of the reference to the Privy Council, that it participates in the nature of references to the law oflftcers of the Crown. Need it be said that it is otherwise with the contentious ju- risdiction of the Judicial Committee, in cases in which that jurisdiction has been conferred upon by statute — the above mentioned case of confirmation or extension of patents, for example — or by common law, as in the somewhat obscure case of the dispute between the provinces cited by Blackstone ? It is true that in these latter cases as well as in that of admi- nistrative reference, the committee renders no judgment, pro- ceeding simply by report, but the report is a matter of form and the sovereign would not be justified in refusing to confirm it by a formal judgment, while it is not so in the case of Letter.] Federal Cbnstitution. 127 voluntary reference, in which, though there is almost always confirmation by the Privy Council, that confirmation is only discretionary and does not become legally binding. If we apply these considerations to the reference to the Supreme Court, what would be the result ? Would that refer- ence made in a matter of legislative jurisdiction, be lawful for the Federal Government? VIII BY VIRTUE OP CLAUSE 52 OF THE SUPREME COURT ACT, THE FEDE- RAL GOVERNMENT HAS NOT THE POWER TO REFER LEGISLA- TIVE QUESTIONS TO THAT TRIBUNAL. Let us specify the question. In the actual state of legislation, has the governor in coun- cil, or, which amounts to the same thing, the Federal Govern- ment, the constitutional power, by virtue of clause 52 of the Supreme Court act, to refer to that court questions arising out of legislative conflicts or between the Federal Parliament and the Provincial Legislatures, and, especially relating to the competence of the former on any given subject, and what would be the effect of the court's opinion on the deliberations of Par- liaments? First of all, the terms of clause 4, which says " that it will be lawful for the Governor in Council to submit to the Supreme Court for hearing or examination all questions whatever that it may judge fit," are so coir»prehenaive that they do not seem to 128 Letters (m th£ interpretcUwn, of the [Third admit of distinction. Nevertheless the spirit of a law modifies and restricts its range, and the execution of a similar law passed in England will aid our inquiry into the intention of the legislator and exercise a great influence on its interpreta- tion. On that score, clause 4 of the Imperial Act 3 and 4 Guil. 4, c. 41, to the intent that "it shall be lawful for the King to refer to the said Judicial Committee for hearing and consideration any other such matter whatever as His Majesty shall think fit," from which our clause is copied, is restricted in prac- tice to executive and administrative matters, as we have already seen. The seven cases of reference made in virtue of this clause which we have quoted all relate to questions of that kind. If we examine all the precedents on the subject, we shall not find a single one relating to legislative matters. Not even all administrative afi'airs or everything trenching on the executive domain is included in it, as the exercise of the royal prerogative of pardon is never referred, as we have already seen. The application of Statutes is everywhere subject to a necessary restriction, whenever their literal application extends beyond the circle of subjects foreseen by the legislator or exceeds the aim of the law. Simple good sense commands this limita- tion. A law may subject the subordinate functionary to the abso- lute authority of the magistrate, a soldier to that of his general officer, an employee of a public department to all orders of his chief of whatever nature, but is it not evident that this authority and those orders must be executed only for the needs of the judicial, military and civil service ? The object and aim of the provision in those cases restricts its application letter.] Federal Constitution. 129 The Governor in Council, that is, the Federal Government, is authorized to refer any question whatever to the Supreme Court. This reference, to have a useful purpose, must be sub- ordinated to the objects that fall within the sphere of its powers and duties, and be ordered to favour the execution of the former and the accomplishment of the hitter. It is in the inte- rest of the Executive Government of the Dominion and to ensure its efficiency, that the Executive Council is authorized to consult the Supreme Court on doubtful questions of law and to profit by its superior legal knowledge. But the subjects on which the opinion of that Court is requested must be circum- scribed within the sphere of the Government's own functions. Now those functions are all administrative and limited to the domain of the Executive Power, without authority in any way to encroach on the legislative domain. The Legislative Power and the Executive Power being essentially distinct, it is only by an accident attributable to the exercise of responsible gov- ernment and not to the nature of the attributes of the two powers, that ministers, as members of the legislatures, take part in legislation, which, according to the doctrine of publi- cists on the division of powers, is altogether alien to them. The reference of article 52 is not. then, made for legislative questions, not to guide the legislatures, whose independence would be unfavorably afiected or even destroyed bv an alien influence. Tt matters little that the House should have .«eemed to hav*' but a vague idea of the nature of tlie reference and that thf author of the amendment proposing it, Sir Hector La ngevin. and Mr. Girouard, who supporter! that amendment and niain- 9 130 Jjetters on the interpretation of the [Third tained the constitutionality of the Federal License Law, should both have seemed to ignore the contentious reference and sus- tained the voluntary and direct reference to the Crown ; the presumption that the House did not mean to adopt a measure legally impossible and unconstitutional will always prevail. IX. DIVERSITY OF OPINIONS IN THE HOUSE AS TO THE MODE OP REFERENCE. TWO SPEECHES ON THAT SUBJECT. It would, however, be difficult to reconcile the diversity of views of the two members as to the steps to be taken in order to legiilize the reference. The report of V Etendard, to which we are indebted for an account of the debate, makes the Minister of Public Works say : " In this manner we shall obtain a deci- " sion from an adequate tribunal. We shall obtain a decision '• from the Supreme Court on the question that the Government " Avill submit to it," and if we are not satisfied with that court, '■ we can go to the Judicial Committee of the Priv> Council. " or we can have a decision from both tribunals ; but. at any '■ rate, we shall obtain a legal decision of authority on the " constitutionality of that Act." " Mr. Girouard. — 1 will vote withtiut hesitation for the " amendment of the Minister of Public Works. Not having '• before us a decision on the constitutionality of the Dominion " License Act, I think we ought to thank the (Government for " preventing so much discussion between the Provincial Gov- '' ernments and the inhabitants of the provinccH (sic)." (I pre- sume that the speaker has been wrongly reported and that he Letter.] Federal Constitution. 131 said : " between the Federal Government and the provinces.) " Instead of having numerous suits and special pleadings in " the different provinces, we shall have only one case and the •■ suit will not commence in an inferior court to be after- " wards carried to a higher court. We shall proceed at once '• before the highest court in the country, the Supreme Court '* of Canada. • Mr. Blake.— How? '' Mr. Girouard. — We shall provide for it by a bill. It cannot '' be done otherwise. I say that it shall be by a bill, for I do •• not know of any other way in which it can be efifected.... I " will not take the opinion of this Parliament en constitutional " (lucstions as a binding authority. I maintain that the tribo- " nals of the country constitute the only known authority for •' the decision of constitutional questions. '' Last year when we had a debate on the King's County (P. •• E. I.) election, certain statutes were cited as unconstitutional, " but I said then that we were not the authority which should " decide the unconstitutionality of those statutes, and that, " consequently, as far as I was concerned, I would consent to '' accept them as the authority of the country until the consti- " tuted authority, that is, the courts of justice of the country, " had decided that they were not constitutional. " We have no authority to do that. The courts of justice '' alone have the right, and T approve of the measure proposed " by the Hon. the Minister of Public Works, which is to carry '* the case before the Supremo Court, and to do so immediatly. " This case will Vje taken before the Supreme Court and the 132 Letters on the interpretati' n, of the [Third " local legislatures shall have the right of being represented by " counsel and to lay their case before that tribunal. I hope " they will do so and that the wliole question of jurisdiction " between the Dominion Parliament and the Local Legislatures " will be discussed. We have an admirable Constitution. We " hear the cry of centralizing tendencies in the Dominion Par- " liament, but such centralization is impossible. *' We have courts of justice to decide with whom the power " lies, whether with the Provincial Legislatures or the Doini- " nion Parliament. In that case the Supreme Court and, I " also hope, the Privy Council will take the question into con- " sideration; for, as the honorable member for Quebec Centre " (Mr. Bosse) has remarked, the people of this country have " the utmost confidence in the decision of the Privy Council, " and that is another reason why this question should be finally " referred to the Privy Council. " If we wish to have a final decision, if we wish the inhabi- " tants of the country to submit to the settlement of this case, '' we ought to have the decision rendered by the Privy Coun- " cil; without that, they will not submit to the decision of the " Supreme Court and they will ultimately appeal it, in their " private cases, to the Privy Council, for the settlement of the •' question now under consideration. " For this reason, I will vote in favour of the amendment of •' the honorable Minister of Public works, and, as I have said, " the members for the Province of Quebec, who are more •' anxious, perhaps, than those of the other provinces, to have " their rights maintained, will vote for this amendment; for, Letter.] Federal Cmstitution. 188 " in the future, when certain rights more sacred than the liquor " trafic shall be in question — I hope that time will never '• come — the members for the Province of Quebec will be able "to rise in Parliament and say: 'Lei m refer this important- " question concerning our insiiiutlons, our religion or our language " to the decision oj the Supreme Court and of the Privy Council," " and I have no doubt that, berore that tribunal, the Province " of Quebec will obtain jusL^ce as well as the other provinces. " For these reasons I shall vote for the amendment of the " Minister of Public Works." ft T. J. J. LO RANGER.