R v Sault Ste-Marie (City of)

R. v. City of Sault Ste-Marie
R v Sault Ste-Marie (City of) [1978] 2 SCR 1299 is a Supreme Court of Canada case where the Court defines the three types of offences that exist in Canadian criminal law and further defines the justification for "public welfare" offences.wikipedia
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Absolute liability

absolute liability principleabsolute" liabilityabsolute-liability
In R. v. City of Sault Ste-Marie, the Supreme Court of Canada defined an absolute liability offence as an offence "where it is not open to the accused to exculpate himself by showing that he was free of fault."

Strict liability (criminal)

strict liabilitycriminal liabilitystrict
In R. v. City of Sault Ste-Marie the Supreme Court of Canada created a two-tiered system of liability for regulatory offenses.

R v Wholesale Travel Group Inc

R. v. Wholesale Travel Group Inc.R. v. Wholesale Travel Inc.
The Court unanimously held that offences for which the mens rea is not necessary (as in cases of reglementary offences (See R v Sault Ste-Marie (City of)) do not violate s. 7 of the Charter when a due diligence defence demonstrated by preponderance of evidence (s.

Supreme Court of Canada

Supreme CourtCanadian Supreme CourtSupreme Court Justice
R v Sault Ste-Marie (City of) [1978] 2 SCR 1299 is a Supreme Court of Canada case where the Court defines the three types of offences that exist in Canadian criminal law and further defines the justification for "public welfare" offences.

Sault Ste. Marie, Ontario

Sault Ste. MarieSault Ste MarieSault Ste Marie, Ontario
The city of Sault Ste. Marie, Ontario, hired Cherokee Disposal to dispose of the city's waste.

Court of Appeal for Ontario

Ontario Court of AppealChief Justice of OntarioChief Justice of Upper Canada
The Court of Appeal for Ontario held that the charge required proof of mens rea, which on the facts would acquit the defendant.

Mens rea

intentmental statemental element
The Court of Appeal for Ontario held that the charge required proof of mens rea, which on the facts would acquit the defendant.

Brian Dickson

Chief Justice DicksonJustice DicksonRobert George Brian Dickson
In the judgement written by Chief Justice Dickson, the Court recognized three categories of offences:

Section 91(27) of the Constitution Act, 1867

criminal law powercriminal lawsection 91(27)
In R. v. City of Sault Ste-Marie, they were classified into the following categories, of which only the first qualifies as criminal (and therefore under federal jurisdiction):

History of the Supreme Court of Canada

history of the CourtProvinces could appeal court rulings
In R v Sault Ste-Marie (City of) [1978] 2 SCR 1299, the court established the standard for strict liability offences in the criminal law.