The respondent dumped woodwaste in provincial marine waters during logging operations and was charged under section 4(1) of the Ocean Dumping Control Act, which prohibits dumping at sea without a permit.
The lower courts held the provision ultra vires Parliament.
The Supreme Court of Canada allowed the appeal, holding that the control of marine pollution by dumping is a single, indivisible matter of national concern that falls within the federal peace, order and good government power.