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Charter

Section 1 — Reasonable Limits on Charter Rights

How every Charter limit is justified or struck down.

Section 1 of the Canadian Charter of Rights and Freedoms guarantees Charter rights subject only to such reasonable limits prescribed by law as can be demonstrably justified in a free and democratic society. Every Charter limitation analysis runs through the proportionality framework articulated in R v Oakes (1986).

The Oakes test asks (1) whether the legislative objective is pressing and substantial, and (2) whether the means are proportionate — meaning rationally connected, minimally impairing, and net-positive in their effects. The party seeking to uphold the limit (typically the government) bears the burden on a balance of probabilities.

Modern jurisprudence applies the Oakes framework with sensitivity to context — the deference owed to legislative judgment varies with the subject matter. Equality, expression and life-liberty cases tend to attract more searching review.

Key principles

  • Pressing and substantial objective
    The objective must respond to a real and important problem.
  • Rational connection
    The means must be logically capable of advancing the objective.
  • Minimal impairment
    The means must impair the right no more than necessary to achieve the objective.
  • Proportionality of effects
    Salutary effects must outweigh deleterious effects on rights.

Cases (5)