The appellant was convicted of wilfully setting fire to material likely to cause a building to catch fire under s. 434(a) of the Criminal Code.
The trial judge found the appellant acted recklessly by burning a large package of clothing in a small fireplace using gasoline while intoxicated, and leaving the fire unattended.
The Court of Appeal upheld the conviction.
The Supreme Court of Canada dismissed the appeal, holding that the appellant's actions met the standard for wilfulness under either an objective or subjective test.