The case involved a sports fisher, fishing in Newfoundland inland waters who was charged with failing to affix a salmon tag to his fish a required by the provincial Wild Life Regulations. In defence, he challenged the constitutional validity of the provincial legislation. The Federal Crown did not intervene.
After reviewing the jurisprudence, the court concluded that the Province and Federal Government had concurrent jurisdiction. In the absence of any conflicting federal legislation to render the provincial legislation inoperative under the paramountcy doctrine, the provincial legislation was enforceable.