JAN 31 2016 REGISTPS
Affidavit #1 of Lynette Tsakoza Affirmed the 26th day of January, 2018 No. 18 0247 Victoria Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: WEST MOBERLY FIRST NATIONS, and ROLAND WILLSON ON HIS OWN BEHALF AND ON BEHALF OF ALL OTHER WEST MOBERLY FIRST NATIONS BENEFICIARIES OF TREATY NO. 8 PLAINTIFFS AND: HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH COLUMBIA, THE ATTORNEY GENERAL OF CANADA, and BRITISH COLUMBIA HYDRO AND POWER AUTHORITY DEFENDANTS AFFIDAVIT #1 OF LYNETTE TSAKOZA I, Lynette Tsakoza, Chief of the Prophet River First Nation, of PO Box 3250, Fort Nelson, BC VOC IRO, British Columbia, AFFIRM AS FOLLOWS: 1.
1 am the Chief of the Prophet River First Nation ("Prophet"), a position I have held since June of 2009. As such, I have personal knowledge of the matters I depose to in this Affidavit except where I say they are based on information and belief, in which case I believe those matters to be true.
2.
Prophet and West Moberly First Nations have stood side by side in opposition to the Site C dam from the beginning of consultations in 2007, participating in each stage of the environmental assessment process though the Council of Treaty 8 Chiefs and subsequently through the Treaty 8 Tribal Association. Together our communities participated in each stage of the environmental assessment process. Myself and Prophet members, including Elders, travelled to give testimony before the Joint Review Panel, although no hearings were held in our community.
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3.
The following Prophet members gave testimony during the Joint Review Panel hearings at various locations: Kalem Bigfoot and Monisha Bigfoot spoke at the hearings in Moberly Lake, former Chief Liza Wolf and Elder Mary McKanacha spoke at Doig River, and 1 gave testimony in Fort St. John.
4.
The fact that no hearings were held in our community is indicative of how Prophet's perspectives and rights were overlooked or diminished during the consultations and environmental assessment carried out for Site C.
5.
As former Chief Liza Wolf stated during the public hearings: we belong to the Peace River. We will protect it for future generations.
6.
Prophet and West Moberly later look joint action in challenging the federal and provincial environmental approvals of the Site C project.
7.
On January 15, 2018, each of our communities filed a Notice of Civil Claim against the
Crown and BC Hydro for infringement of Treaty 8. 1 am the representative plaintiff in the action filed by Prophet: Prophet River First Nation et al v. Pier Majesty the Queen in Right of the Province of British Columbia et al ., Victoria Registry Action No. 18-0248. A
copy of Prophet's Notice of Civil Claim is attached to this Affidavit as Exhibit "A". 1 understand that our lawyers are seeking to have Prophet's action case managed together with West Moberly's action.
8.
Taking action to protect our treaty rights is expensive. To best focus our limited
resources, we have decided to proceed with only one injunction application to stop or limit construction on Site C until a court can make a final determination on the question
of Treaty infringement. West Moberly is bringing this application and we support it fully.
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9.
1 affirm this affidavit to indicate my support for West Moberly's application and to explain why Prophet has not brought its own.
AFFIRMED BEFORE ME at Victoria, in the
Province of British Columbia, on this 26th day of January, 201 8.
A Commissioner for Taking Affidavits in British Columbia
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NETTE TSAICOZA
Exhibit "A" referred to in the Affidavit of Lynette Tsakoza, sworn/affirmed before
me at
SUPREME COURT OF BRITISH COLUMBIA
BC this
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,
day of January, 2018
A Commissioner for taking Affidavits within British Columbia
VICTORIA REGISTRY
18 0248 No.
Victoria Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA
JAN 1 5 2018 BETV EEN:
S3 TROPHET RIVER FIRST NATION, and LYNETTE TSAKOZA ON HER OWN BEHALF AND ON BEHALF OF ALL OTHER PROPHET RIVER FIRST NATION BENEFICIARIES OF TREATY NO. 8
PLAINTIFFS AND: HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH COLUMBIA, THE ATTORNEY GENERAL OF CANADA, and BRITISH COLUMBIA HYDRO AND POWER AUTHORITY
DEFENDANTS NOTICE OF CIVIL CLAIM
This action has been started by the plaintiff(s) for the relief set out in Part 2 below. If you intend to respond to this action, you or your lawyer must
(a)
file a response to civil claim in Form 2 in the above-named registry of this court within the time for response to civil claim described below, and
(b)
serve a copy of the filed response to civil claim on the plaintiff(s).
If you intend to make a counterclaim, you or your lawyer must
(a)
file a response to civil claim in Form 2 and a counterclaim in Form 3 in the abovenamed registry of this court within the time for response to civil claim described below, and
(b)
serve a copy of the filed response to civil claim and counterclaim on the plaintiff(s) and on any new parties named in the counterclaim.
JUDGMENT iVLAY BE PRONOUNCED AGAINST YOU IF YOU FAIL to file the response to civil claim within the time for response to civil claim described below. Time for response to civil claim
A response to civil claim must be filed and served on the plaintiff(s), (a)
if you were served with the notice of civil claim anywhere in Canada, within 21 days after that service,
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(b)
(c)
if you were served with the notice of civil claim anywhere in the United States of America, within 35 days after that service, if you were served with the notice of civil claim anywhere else, within 49 days after that service,
(d)
if the time for response to civil claim has been set by order of the court, within that time.
CLAIM OF THE PLAINTIFFS Part 1: STATEMENT OF FACTS The Parties
The Plaintiffs 1.
The Plaintiff Prophet River First Nation ("Prophet") is a "band" as defined in the Indian
Act, RSC 1985, c 1-5, and is an "Aboriginal people" within the meaning of section 35 of the
Constitution Act, 1982, being Schedule B to the Canada Act 1982 (UK), 1982, c 1 1. Prophet adhered to Treaty 8 in or about 1910 and/or 1911.
2.
The Plaintiff Lynette Tsakoza is the duly elected Chief of Prophet, a registered Indian,
and a member of Prophet. She brings this action on her own behalf and as a representative on
behalf of all other Prophet beneficiaries of Treaty 8.
The Defendants 3.
The Defendant Her Majesty the Queen in Right of the Province of British Columbia
("British Columbia") is named in this proceeding pursuant to s. 7 of the Crown Proceedings Act, RSBC 1996, c 89, and is that emanation of the Crown that holds the beneficial interest to the lands and waters material to the issues in this proceeding, subject to the interests of the Plaintiffs. 4.
British Columbia has power to manage and regulate the lands and waters material to the
issues in this proceeding pursuant to ss. 109, 92(5) and 92A of the Constitution Act, 1867, and subject to s. 35 of the Constitution Act, 1982 and Treaty 8.
5.
The Defendant British Columbia Hydro and Power Authority ("BC Hydro") is a British
Columbia Crown coiporation, continued pursuant to s. 2 of the Hydro and Power Authority Act, RSBC 1996, c 212, and is for all its purposes an agent of the government of British Columbia in
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accordance with s. 3 of the Hydro and Power Authority Act, RSBC 1996, c 212. British Columbia is responsible for the actions of BC Hydro undertaken as British Columbia's agent.
6.
The Attorney General of Canada is the representative of Her Majesty the Queen in right
of Canada ("Canada"), and is named in this proceeding pursuant to section 23(1) of the Crown Liability and Proceedings Act, RSC 1985, c C-50. Canada has power to manage and regulate the
lands and waters material to the issues in this proceeding pursuant to s. 91 of the Constitution Act, 1867, including its jurisdiction over navigation and shipping, sea coast and inland fisheries, and "Indians, and Lands reserved for the Indians", subject to s. 35 of the Constitution Act, 1982 and Treaty 8.
Treaty 8
7.
Treaty 8 (or the "Treaty") is a treaty within the meaning of s. 35 of the Constitution Act,
1982. Treaty 8 was originally made and concluded in 1899 at Lesser Slave Lake between Her most Gracious Majesty the Queen of Great Britain and Ireland ("the Crown") and the Chief and Headmen of the Indians of Lesser Slave Lake and adjacent country. The Treaty was ratified by Order in Council 363 on February 2, 1900.
8.
In approximately 1910 and/or 1911, Dunne-za ancestors of the present-day Prophet
adhered to Treaty 8.
9.
Treaty 8 created reciprocal rights and obligations on the part of Prophet and the Crown.
1 0.
The Crown required and sought the consent of Prophet's ancestors to open the tract of
land which the Crown wished to use and inhabit for settlement and other activities. 1 1.
The Plaintiffs' ancestors gave this consent in exchange for the solemn promises made by
the Crown, including that:
a)
entrance into Treaty 8 would not lead to forced interference with the Plaintiffs' mode
of life;
b)
the same patterns of activity would continue for the Plaintiffs' ancestors and their descendants after the Treaty as existed before it; and
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c)
the Plaintiffs would be as free to hunt, trap, and fish as they had been before entering the Treaty.
Centrality of the Peace at the time of Treaty 12.
At the time of their adherence to Treaty 8, the Peace River was the central river in the
region, navigated by the Dunne-za, other Indigenous peoples, settlers, and trappers. For Prophet's ancestors, the Peace River was not merely a "river highway" or resource from which they drew.
The Peace River, its islands, surrounding lands, and confluences with certain tributaries, including the Finlay, Parsnip, and Moberly Rivers (collectively the "Peace"), was unique and
central to the mode of life and cultural landscape of the Plaintiffs ancestors, which defined their history, knowledge, and traditional practices. The Plaintiffs' ancestors used and relied upon the Peace for their hunting, trapping, fishing, gathering, navigation, habitation, teaching, and ceremonial, spiritual, cultural and other traditional practices.
13.
In entering into Treaty 8, the Plaintiffs' ancestors would not and could not have
understood that the Crown could "take up" or destroy the Peace. Such activity was not contemplated by the terms of the Treaty, nor did the Crown ever communicate this as part of
negotiations or otherwise.
Treaty Rights 14.
The Crown's solemn promises, in the context in which they were provided, guarantee the
Plaintiffs' rights to meaningfully:
a)
continue their mode of life, including patterns of activity and occupation, without forced interference;
b)
maintain and access teaching, cultural, spiritual, and community gathering sites in order to pass on the Plaintiffs' mode of life;
c)
maintain access to resources and places which have a unique and central significance
to their hunting, fishing, and trapping, or other aspects of their mode of life;
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d)
hunt, fish, gather, and trap within their traditional territory, which includes travel on and access to the lands, habitat, ecosystems, trails, waters, and other infrastructure of the Peace;
e)
maintain their practical, cultural, and spiritual connection to the Peace; and
f)
conduct traditional, cultural, and spiritual activities at or in connection with the Peace
(the "Treaty Rights").
15.
Pursuant to Treaty 8, the Defendants' obligations include the obligation:
a)
to act honourably, ensuring that the enactment of regulations and the taking up of land
do not interfere with the Plaintiffs' continued meaningful exercise of Treaty Rights; b)
to manage and protect the lands designated under the Treaty, and adjacent lands,
including the waters and ecosystems within those lands, in such a way as to: i. ii.
c)
minimize impacts on Treaty Rights, and ensure the continued meaningful exercise of Treaty Rights by the Plaintiffs;
not to displace the Plaintiffs, forcibly interfere with their mode of life, or permit the doing of these things;
d)
not to interfere with the Plaintiffs' traditional patterns of activities; and
e)
not to interfere, or allow others to interfere, with the Plaintiffs' meaningful exercise of Treaty Rights.
Prophet and the Peace
16.
After adherence to Treaty 8, the Peace continued to have a unique and central
significance to the practices and mode of life of the Prophet and their Dunne-za ancestors. The Plaintiffs and their ancestors maintained a physical, practical, cultural, and spiritual connection
to the Peace. The Peace is necessary for the meaningful exercise of some or all of the Plaintiffs' Treaty Rights.
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Damming of the Peace River
17.
British Columbia enacted and enacts legislation governing the production, transmission,
distribution, and regulation of electricity in British Columbia.
18.
In or around 1 962, British Columbia created BC Hydro as a Crown corporation, in part to
enable the development of hydroelectric construction projects on the Peace River.
19.
In or around 1968, BC Hydro completed the W.A.C. Bennett Dam at the head of the
Peace River Canyon ("Bennett Dam"), approximately 50 km northwest of the Reserve.
20.
The Bennett Dam flooded the Peace River to the north and west of the dam, as well as the
Parsnip and Finlay Rivers, to create British Columbia's largest reservoir, the Williston Reservoir.
The Bennett Dam and Williston Reservoir caused extensive changes to the environment and landscape in and around the Peace River system, flooding lands previously used by wildlife and the Prophet, and resulting in a fundamental change to the aquatic ecosystem. Construction of the Bennett Dam and creation of the Williston Reservoir significantly impacted and continue to significantly impact Prophet's ability to meaningfully exercise Treaty Rights.
21.
British Columbia and Canada granted the necessary approvals for BC Hydro to construct
the Bennett Dam, but failed to adequately consult with or accommodate Prophet.
22.
In or around 1980, BC Hydro completed the Peace Canyon Dam on the Peace River,
approximately 21 km downstream from the Bennett Dam near the foot of the Peace River
Canyon. The Peace Canyon Dam is approximately 25 km north of the Reserve.
23.
The Peace Canyon Dam flooded the section of the Peace River between the Peace
Canyon Dam and the Bennett Dam, forming Dinosaur Lake Reservoir over lands previously used by wildlife and the Prophet, and resulting in a fundamental change to the aquatic ecosystem. Construction of the Peace Canyon Dam and creation of the Dinosaur Reservoir significantly impacted and continue to significantly impact Prophet's ability to meaningfully exercise Treaty Rights.
24.
British Columbia and Canada granted the necessary approvals for BC Hydro to construct
the Peace Canyon Dam, but failed to adequately consult with or accommodate Prophet.
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The Site C Dam
25.
By 1978, BC Hydro had identified Site C, approximately 7 km southwest of Fort St.
John, as a potential location for a third dam on the Peace River. In 1980, BC Hydro applied for
an Energy Project Certificate to initiate Site C dam construction. BC Hydro's application was referred to the British Columbia Utilities Commission ("BCUC"), the independent agency responsible for regulating electric utilities pursuant to the Utilities Commission Act, SBC 1980, c. 351. hi 1983, the BCUC recommended against issuance of an Energy Project Certificate until
future demand forecasts could justify an immediate start to construction, and only after consideration of energy supply alternatives demonstrated that Site C would be the best project to meet anticipated shortfalls. The BCUC recommended that any determination of these matters be referred to the BCUC for further consideration.
26.
BC Hydro did not receive authorization to initiate Site C dam construction at that time.
27.
BC Hydro continued to consider the Site C project internally in subsequent decades. In or
around the late 2000s, BC Hydro began meeting with First Nations about Site C. 28.
In 2010, through s. 7(1 )(d) of the Clean Energy Act, SBC 2010, c 22, British Columbia
exempted Site C from requiring a certificate of public convenience and necessity from the BCUC under the Utilities Commission Act.
29.
In 2010, BC Plydro began submitting its Site C project plans for regulatory and
environmental reviews, including under the British Columbia Environmental Assessment Act, SBC 2002, c 43, and the Canadian Environmental Assessment Act, SC 1992, c 37. A Federal-
Provincial Joint Review Panel was established in August 2013 but was not mandated to consider whether the electricity to be produced at Site C was required, whether other means were available to meet British Columbia's energy needs, or whether Site C would infringe Prophet's Treaty Rights.
30.
In May 2014, the Joint Review Panel concluded that Site C would have significant
adverse environmental effects and significant adverse effects on Prophet that could not be mitigated.
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31.
In October 2014, Canada issued its Environmental Assessment Decision Statement,
revised and re-issued on November 25, 2014 under s. 54 of the Canadian Environmental Assessment Act, 2012 , SC 2012, c 19, approving Site C with conditions. Canada has issued, or is
expected to issue, further approvals to permit construction of Site C. 32.
On October 14, 2014, British Columbia issued an Environmental Assessment Certificate
for Site C.
33.
In December 2014, British Columbia made its final investment decision in favour of Site
C. British Columbia has issued, or is expected to issue, further approvals to permit construction of Site C.
34.
In issuing their approvals for Site C, neither British Columbia nor Canada assessed
whether Site C would infringe Prophet's Treaty Rights.
35.
On August 2, 2017, by way of Order in Council 244 ("OIC 244") pursuant to s. 5(1) of
the Utilities Commission Act, RSBC 1996, c 473, the Lieutenant Governor in Council requested
the BCUC to advise in respect of Site C. OIC 244 did not permit the BCUC to consider:
36.
a)
whether BC Hydro's demand forecast is accurate;
b)
the full range of energy supply alternatives;
c)
whether a certificate of public convenience and necessity should issue; or
d)
whether Site C infringes Treaty rights.
On November 1, 2017, the BCUC reported in accordance with OIC 244 and advised that
BC Hydro's demand forecast could be satisfied through an alternative portfolio of assets and other mitigation strategies, and that the potential cost to ratepayers of this alternative portfolio would not necessarily be greater than the expected costs associated with Site C.
37.
On December 1 1, 2017, British Columbia announced its decision to complete Site C.
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Specific impacts of the Site C Dam
38.
Completion of the Site C Dam will result in the flooding of an additional 83 km of the
Peace River. Another reservoir will be created west of the Site C dam to Peace Canyon Darn. Amongst other impacts, Site C and the associated reservoir will:
a)
destroy the existing aquatic ecosystem and result in a new aquatic ecosystem and fish community;
b)
destroy fish habitat;
c)
reduce fish density, making it more difficult to find and catch fish in the reservoir;
d)
increase mercury levels in the reservoir for at least 15 to 25 years, with bioaccumulation in fish;
e)
flood the lower reaches of several tributaries, which will become methylating,
resulting in fish moving upstream with the same methylmercury concentration levels
as in the reservoir itself;
f)
pose a risk to health through methylmercury contamination if fish are consumed in accordance with Prophet's traditional practices;
g)
extirpate multiple fish species preferred by Prophet;
h)
prevent Prophet from harvesting preferred species of fish;
i)
disrupt boat and shore-based river fishing and practices along the proposed reservoir and tributaries;
j)
destroy at-risk and sensitive communities, including wetlands, riparian and floodplain forests, tufa seeps, and mark fen;
k)
destroy plants gathered by Prophet for spiritual, medicinal and food purposes;
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1)
destroy critical habitat for caribou, weakening the prospects for the recovery of caribou already facing extirpation as a result of the cumulative impacts of the Bennett Dam and other development in the region;
m)
pose significant risk to the survival of other at-risk species;
n)
inundate or restrict access to habitation sites associated with the exercise of Treaty Rights;
o)
destroy spiritual and cultural sites, including those used for gatherings and teachings;
p)
inundate traditional trails, navigation routes, and spring water sources important to Prophet when using the land to exercise Treaty Rights; and
q)
exclude or undermine Prophet's ability to hunt and trap preferred species in a unique and centrally significant area, and require members to travel to more distant or less suitable lands and waters to pursue hunting and trapping.
Infringement of Treat}' Rights
39.
The Site C Dam, in conjunction with the ongoing impacts from the Bennett and Peace
Canyon Dams, will result in:
a)
no meaningful ability of Prophet to exercise some or all of their Treaty Rights;
b)
loss of Prophet's use and enjoyment of lands and waters (including the Peace), which are of central significance to their traditional territory;
c)
displacement of Prophet hunters, trappers and fishers;
d)
disruption and curtailment of the continuity of Prophet's patterns of activities;
e)
loss of Prophet's preferred means of exercising then Treaty Rights; and
f)
forcible interference with Prophet's mode of life.
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40.
The cumulative impact of the Bennett, Peace Canyon, and Site C Dams is to turn the
Peace River into a series of reservoirs, destroying the unique cultural and ecological character of the Peace, severing the physical, practical, cultural and spiritual connection the Prophet have
with the Peace, and infringing Prophet's Treaty Rights.
Part 2: RELIEF SOUGHT WHEREFORE the Plaintiffs claim as follows:
A declaration that, in causing and/or permitting the cumulative impacts of the Bennett,
1.
Peace Canyon, and Site C Dams on the Plaintiffs' Treaty Rights, the Crown Defendants have:
a)
failed to uphold the Honour of the Crown;
b)
breached their obligations to Prophet under the Treaty; and
c)
unjustifiably infringed Prophet's Treaty Rights.
2.
A declaration that any Crown action, decision, or approval permitting the construction or
operation of the Site C Dam is unconstitutional, void, and of no force and effect on the grounds that it:
a)
fails to uphold the Honour of the Crown;
b)
breaches the Crown's obligations to Prophet under the Treaty, and
c)
unjustifiably infringes Prophet's Treaty Rights.
3.
An interim, interlocutory and/or permanent injunction prohibiting Canada and British
Columbia from issuing any approvals required for the construction, completion, or operation of SiteC.
4.
An interim, interlocutory and/or permanent injunction prohibiting BC Hydro from
continuing or completing construction of Site C and flooding the Peace River.
5.
Costs.
6.
Such further and other relief as this Honourable Court may deem appropriate.
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Part 3: LEGAL BASIS
1.
The Constitution Act, 1982, recognizes and affirms the existing treaty rights of the
Aboriginal peoples of Canada.
2.
The Defendants are bound by Treaty 8, as both levels of government are responsible for
fulfilling the promises in the Treaty, in accordance with the division of powers under the Constitution Act, 1867 (UK), 30 & 31 Vict, c 3, reprinted in RSC 1985, App 11, No 5.
3.
The Plaintiffs have rights under the Treaty against the curtailment by the Crown of the
mode of life that the Plaintiffs enjoyed before entering the Treaty.
4.
The exercise of the Defendants' rights under the Treaty, including any rights to make
regulations or to take up lands, are subject to and burdened by the Defendants' obligations to the
Plaintiffs under the Treaty, the Constitution, and the honour of the Crown. The Defendants must act in a way that seeks to preserve and accomplish the intended purposes of the Treaty and to ensure the continuing meaningful exercise of the Treaty Rights by the Plaintiffs. 5.
The damming of the Peace is outside the scope of Crown actions permitted by the "taking
up" clause contained in Treaty 8, and constitutes a breach and infringement of the Treaty and the
Plaintiffs' Treaty Rights, contrary to the Defendants' constitutional obligations and the honour of the Crown.
6.
In the alternative, the cumulative impacts of the Bennett, Peace Canyon, and Site C Dams
constitute the taking up of land to such an extent as to breach and infringe the Treaty and the Plaintiffs' Treaty Rights, contrary to the Defendants' constitutional obligations and the honour of the Crown.
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Plaintiffs' address for service: Camp Fiorante Matthews Mogerman
Woodward and Company Lawyers LLP
#400 - 856 Homer Street
Suite 200, 1022 Government Street
Vancouver, BC
Victoria, BC
Canada V6B 2W5
Canada V8W 1X7
Attention: Reidar M. Mogerman,
Attention: Sonya Morgan,
Counsel for the Plaintiffs
Co-counsel for the Plaintiffs
Fax number address for service:
(604) 689-7554
Camp Fiorante Matthews Mogerman (250) 380-6560 Woodward and Company Lawyers LLP
Place of trial:
Victoria
The address of the registry is:
Victoria Law Courts 850 Burdett Ave PO Box 9248
Stn Prov Govt x5naTBC-V8V
Dated: January 15, 2018
Reidar M. Mo]|eruW Camp Fiorante Matthews Mogerman Counsel for the Plaintiffs
Rule 7-1 (1) of the Supreme Court Civil Rules stales: (1) Unless all parties of record consent or the court otherwise orders, each party of record to an action must, within 35 days after the end o f the pleading period, (a)
prepare a list of documents in Form 22 that lists (i) all documents that are or have been in the party's possession or control and that
could, if available, be used by any party at trial to prove or disprove a material fact, and
(ii) all other documents to which the party intends to refer at trial, and (b) serve the list on all parties of record.
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Part 1:
CONCISE SUMMARY OF NATURE OF CLAIM:
A claim that Site C infringes the Plaintiffs' Treaty 8 rights. The Plaintiffs seek declaratory and injunctive relief.
Part 2:
THIS CLAIM ARISES FROM THE FOLLOWING:
A personal injury arising out of: [ ] a motor vehicle accident [ ] medical malpractice [ ] another cause A dispute concerning: [ ] contaminated sites [ ] construction defects [ ] real property (real estate) [ ] personal property
[ ] the provision of goods or services or other general commercial matters
[ ] investment losses [ ] the lending of money [ ] an employment relationship
[ ] a will or other issues concerning the probate of an estate [X] a matter not listed here
Part 3: THIS CLAIM INVOLVES: [ ] a class action
[ ] maritime law [X] aboriginal law [X] constitutional law [ ] conflict of laws [ ] none of the above
[ ] do not know
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Part 4:
Constitution Act, IS67 Constitution Act, 1982