The appellant challenged the constitutional validity of the Heroin Treatment Act, a British Columbia statute providing for the compulsory treatment and detention of heroin users.
The Supreme Court of Canada held that the Act was intra vires the provincial legislature.
The Court found that the pith and substance of the legislation was the medical treatment of heroin addicts, which falls within the province's general jurisdiction over health matters under section 92(16) of the British North America Act, 1867.
The compulsory aspects of the treatment were deemed incidental to its effectiveness and not a colourable attempt to enact criminal law.
