Roderick A. McLennan

The Minister of National Revenue assessed the respondent taxpayers under s. 160 of the Income Tax Act for taxes owing by a company from which they had received payments.

The taxpayers applied for judicial review of the Minister's discretionary decision to assess them, arguing that the long delay before the assessment was abusive.

The Supreme Court of Canada held that judicial review was not available because s. 160 expressly allows the Minister to assess 'at any time', meaning there is no limitation period.

Furthermore, the taxpayers could have pursued the regular tax appeal process to challenge the assessments.

The Province of Alberta challenged the constitutionality of the federal Firearms Act, which required the licensing and registration of all firearms, including ordinary rifles and shotguns.

Alberta argued the law fell under provincial jurisdiction over property and civil rights.

The Supreme Court of Canada upheld the legislation as a valid exercise of Parliament's criminal law power.

The Court found the pith and substance of the law was directed to enhancing public safety by controlling access to firearms through prohibitions and penalties, and its effects on provincial jurisdiction were merely incidental.