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Toronto Electric Commissioners v Snider, [1925] UKPC 2

Facts:

Industrial Disputes Investigation Act – allowed for investigation, when a board was appointed a strike or lockout was not allowed

Issue(s):

Is the act a justified exercise of Dominion power?

Ratio:

Prima facie jurisdiction of labour relations falls to the provinces (Parson and Snider)

Analysis:

s.91 for POGG
**Not open to treat Russell as having established the general principle that the mere fact that Dominion leg is for the general advantage of Canada, renders it competent if it cannot be found in s.91

Holding:

Appeal allowed – T can get injunction – act struck down – Act is ultra vires


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