The appellants, police officers, sought to quash a provincial Order in Council establishing a commission of inquiry into the alleged assault of a prisoner while in police custody.
They argued the inquiry was ultra vires the province as it intruded into federal jurisdiction over criminal law and procedure.
The Supreme Court of Canada held that the province has the constitutional authority under s. 92(14) and s. 92(6) of the Constitution Act, 1867 to establish an inquiry to investigate and report on alleged wrongdoings by members of a provincial police force.
The inquiry's purpose was not to determine criminal responsibility but to investigate police misconduct that undermined the administration of justice.
