The appellant was convicted of unlawful possession of restricted weapons after police found unregistered handguns in his home.
He challenged the constitutionality of section 106.7(1) of the Criminal Code, which placed the onus on the accused to prove they held a valid registration certificate, arguing it violated the presumption of innocence under section 11(d) of the Charter.
The Supreme Court of Canada dismissed the appeal, holding that the provision did not impose an impermissible reverse onus because the production of a certificate resolves all doubts in favour of the accused and provides an absolute defence.
Alternatively, the Court found that any infringement would be justified under section 1 of the Charter.
