The respondent sued the appellant for price discrimination under s. 31.1 of the Combines Investigation Act, which creates a civil cause of action for certain infractions of the Act.
The appellant challenged the constitutional validity of s. 31.1, arguing it fell under provincial jurisdiction over property and civil rights.
The Supreme Court of Canada held that the Combines Investigation Act is valid federal legislation under the general trade and commerce power (s. 91(2) of the Constitution Act, 1867).
The Court further held that s. 31.1 is intra vires Parliament because it is functionally related to the general objective of the legislation and is an integral part of the regulatory scheme.