Article Volume 2:1

The Constitutional Background of Taxation Agreements

Table of Contents

THE McGILL
LAW JOURNAL

VorAumrs 2

AUTUMN 1955

NUMBER 1

THE CONSTITUTIONAL BACKGROUND OF

TAXATION AGREEMENTS

F. R. Scott*

The financial relations between Ottawa and the provincial governments
form one of the most complex and changing aspects of Canadian federalism.
Within two years after Confederation the original terms of Union, set out in
Sec. 118 of the B.N.A. Act, were varied to accommodate the claims of Nova
Scotia, and since then no constitutional provision or political agreement has
endured for long, whether it has been declared in the law of the constitution,
as in 1867, to be “in full and final settlement”, or whether, as in 1907, this
firm intention was prudently withdrawn from the text of the amendment, at
the request of British Columbia. Indeed, the new form of these financial
arrangements that was adopted after World War II, based on the tax rental
idea and renewable every five years, was the first serious attempt ever made in
Canada to discover a method by which some order and stability might be
introduced into a relationship which otherwise changes in an erratic and un-
planned manner. The Sirois Report proposed another solution, but this was
rejected in 1940. That the recent attempt has been only partially successful
is evident from the fact that no general formula was found acceptable to all
the provinces.

At a time when new financial terms are being negotiated in Canada, it may
be useful to examine the law of the constitution within which any revised
arrangements will have to operate. This law could, of course, be changed by
constitutional amendment, as in 1907, but it is doubtful if such a course will
be followed. Amending the constitution is one of those complexes in the
Canadian psyche which we prefer to thrust down deep into our political sub-
conscious, and no sofa has yet been devised on which we seem able to liberate
our internal conflicts. Any new tax agreements we adopt are therefore likely to
have to be fitted into the old law. This leaves a very wide area where solutions
can be found based on consent, since the legal rules are relatively few. Never-
theless consent cannot be given contrary to the law, nor can it rest on founda-

*Macdoniald Professor of Law, McGill University.

[Vol 2
tions more secure than those which the federal framework provides. It is to
these basic constitutional rules, therefore, that attention will be turned.

McGILL LAW JOURNAL

TAXING POWERS IN THE B.N.A. ACT

Leaving aside minor variations, the principle ideas in the BN.A. Act
regarding the financial powers and the fiscal relations of the federal qn4
provincial governments may be stated simply. The Parliament of Canada M Y
adopt any mode or system of taxation it chooses, be it direct or indirect,
progressive or regressive, fair or discriminatory. The provinces are limited to
direct taxation within the province in order to the raising of revenue for
provincial purposes, and in addition have a general licensing power for the
same purposes. Provinces may also gather the royalties and income from the
sale and development of their natural resources (s. 109). All provinces were
granted subsidies in 1867, at so much per head of population, calculated at an
amount enabling provincial budgets to be balanced with the then existing
provincial responsibilities. All provincial debts were assumed by Ottawa so
that every provincial government started its federal life debt free. But provinces
were given power to borrow on the sole credit of the province (s. 92-3) and
no restriction was placed upon the total amount that might be raised in this
manner, nor upon the location of the lender. Hence provinces may incur in-
ternational debts. It was not believed in 1867 that the needs of local govern-
ment would be great, or that there was any danger of provincial fiscal policies
endangering national economic plans. Jurisdiction over credit generally,
through banks, currency and the issue of paper money, was in federal hands,
along with control of interest. Both Parliament and the legislatures were
prohibited from imposing any tax on Crown property (s. 125).

It is clear from these initial provisions of the constitution that the concept
of provincial autonomy prevailing at Confederation was subject to two im-
portant financial restrictions; first in being limited to direct taxation, and
secondly in being dependent on subsidies. On the other hand, the taxing powers
of Parliament appeared unlimited. This is the reverse of the situation found
in the American constitution, where the States may impose direct or indirect
taxes, and where there were limitations on the right of Congress to tax which
necessitated the XVIth amendment authorising federal income taxes. The
notion of subsidies, substantial in relation to the original provincial budgets,
which was basic to the Canadian scheme, is all the more surprising in view of
the sound parliamentary tradition with us that the .government which spends
public money should be compelled to raise it.’ In the United States as well
as in Switzerland and Australia, however, though no subsidies were provided
in the constitution, it has since been found necessary for the central govern-
ment to make voluntary grants to the states in proportions comparable to
those paid in Canada under the tax agreements. 2

‘See comment Sirois Report, Book II, p. 126.
2Wheare, Federal Govt. 3rd ed. pp. 115-6.

No. I1]

TAXATION AGREEMENTS

VARIATIONS IN FINANCIAL STATUS OF PROVINCES

While in general the taxing powers of all provinces are equal, it was found
impossible from the first to apply uniform rules across Canada. By s. 124 of
the B.N.A. Act New Brunswick was permitted to levy lumber dues not allowed
to other provinces. The natural resources of the western provinces were
handed back in 1930 subject to limitations from which the other provinces
were free. As the Privy Council said in 1953, when holding that Saskatchewan
was prevented by its constitution from taxing C.P.R. properties, “There was
thus no set pattern of ‘a Province’ in the Act of 1867”,3 a remark which does
not quite square with Mr. St. Laurent’s comment at his Reform Club speech
in the autumn of 1954 that Quebec was “a province like other provinces”.
There are very few provinces exactly like other provinces in their constit-
utional position, though it is true that the taxing powers of the four original
provinces were the same with the one exception for New Brunswick already
noted.

Thus it is not surprising to find that when the taxation agreements were
negotiated in 1942 and 1947 there were two options available, and in 1952
three options, later increased to four to accommodate Quebec’s income tax.
Perhaps when we reach ten options we shall achieve a truly Canadian un-
animity. How far these variations are compatible with the maintenance of
something we can call national fiscal policy designed to maintain high em-
ployment it is not for the constitutional lawyer to say, but it is clear that the
present constitution does not give Ottawa the legal power to implement a
policy that controls provincial taxing powers, except with provincial consent.

RESULTS OF CONSTITUTIONAL INTERPRETATIONS

The results of judicial decisions on the tax clauses of the B.N.A. Act may
perhaps be summarized without serious inaccuracy by saying that the courts
have somewhat reduced the wide taxing powers of Parliament, and have
permitted some extensions of the limited powers of the provinces but not
enough to keep pace with the vastly increased costs of provincial government.
Federal power has been diminished by the application of the doctrine that
particular words override more general ones and operate by way of exception
to them. Hence Ottawa cannot impose a direct tax within a province in order
to the raising of a revenue for provincial purposes.4 It can, however, impose a
direct tax in order to raise a revenue for a federal purpose. What then is a
provincial purpose? Curiously enough this term has never been authoritatively
defined by the courts; if it means merely “for the exclusive disposition of the
legislature”, as Duff C.J. said it meant in the Unemployment Insurance

3A.-G. for Sask. v. Canadian Pacific Rly. Co. [1953] A.C. 594 at p. 613. Saskatchewan
and Alberta are compelled by their constitutions to accord the C.P.R. a degree of fiscal
respect elsewhere reserved for royalty.
4Caron v. The King [1924] A.C. 999.

McGILL LAW JOURNAL

[Vol. 2

Reference, 5 then indeed the Dominion and Provincial powers of taxation are on
different planes and cannot come into conflict. However, there was an obscure
remark in the Privy Council judgment in the same case indicating that just
because the Dominion has collected a fund by means of taxation, it by no
means follows that any legislation which disposes of it is necessarily valid.
The first unemployment insurance act, which raised such a fund, was un-
constitutional, but chiefly on the ground that it interfered with the contract of
employment. Obviously, not every federal statute is valid just because it
authorizes the expenditure of public funds, which is all the Privy Council has
actually said, but the manner of their saying it has raised some doubt as to the
validity of social insurance schemes paid for out of federal revenues. It should
be noted, however, that the legal doctrine referred to which limits federal
powers by excepting from thdm specific provincial powers, only applies to
direct taxes; indirect taxes escape its application, since the provinces cannot
impose them at all.

Turning to the provincial taxing powers, it is evident that once the courts
had classified sales taxes as direct taxes when they were based on the device
of making the vendor a tax collector, a wide new field for taxation was open
to provincial governments. This is a strange result in a country where excise
taxes are reserved to the central government, since both types of tax have
much the same economic effect on consumption. In New Brunswick a man
who opens in his own home a package of cigarettes imported from another
province is supposed immediately to pay his New Brunswick tax., British
Columbia succeeded in imposing a tax on consumers of fuel oil which was in
fact being imported free into the province.7 Thus in effect the provinces can
impose a custom barrier around themselves despite the explicit reservation of
customs to Ottawa in s. 122 of the constitution. The courts also approved
provincial taxes on banks, federal civil servants and judges, thus rejecting for
Canada any doctrine of the “immunity of instrumentalities”. On the other hand,
the courts did not allow provinces to breach the tariff wall by the simple
process of taking ownership of the imports in the name of the Crown and
claiming exemption under s. 125. Had the reverse ruling obtained, socialism
for fiscal purposes might have developed at the provincial level much more
rapidly.
I Despite these enlarged interpretations of their powers, provinces have had
great difficulty in increasing their revenues as fast as their enlarged govern-
mental functions, also due in part to judicial interpretation, have accumulated.
This explains why, of the three formal amendments to legislative powers in
the B.N.A. Act since 1867, two have concerned costly social insurances, namely

5 Unemployment Insurance Reference [1936] S.C.R. at p. 434.
Atlantic Smoke Shops v. Conlon [1943] A.C. 550.
7A.-G. for B.C. v. Kingcome Navigation Co. [1934] A.C. 45; see also my comment in

(1934), 12 Can. Bar Rev. 303.

No. I1]

TAXATION AGREEMENTS

unemployment insurance (1940) and old age pensions (1951).
(The third
was the 1949 addition of the federal amending clause). Health insurance
would be another very costly undertaking, and while, it is submitted, it could
be established without an amendment, by a system of grants in aid financed
through income tax and general revenue, federal administrators would no
doubt feel happier with some agreed transfer of jurisdiction.

LEGAL NATURE OF TAXATION AGREEMENTS

The Parliament of Canada and provincial legislatures, being sovereign in
their own spheres and incapable of binding their successors, cannot place
taxation schemes on any but a “gentlemen’s agreement” basis. Despite the
concurrent statutes giving effect to the agreements, nobody is really bound in
law to maintain them. Hence no loss of sovereignty takes place when a province
enters an agreement, any more than it takes place when a province leases
natural resources to an American corporation. The restraint imposed comes
from the economics, not the law of the situation. British Columbia was held
to be able to impose a tax on the Vancouver Island railway belt even though
it bad passed a self-denying statute in 1883 as part of a scheme for aiding
railway construction. 8 Quebec’s acceptance of the Wartime Agreements in
1942 did not prevent her refusing the subsequent ones in 1947 and 1952.

The most startling proof of the purely voluntary nature of taxation
agreements, however, was furnished by the federal government itself, when
in January, 1945 it suddenly refused to pay to Saskatchewan the monies
promised under the Wartime Tax Agreement of 1942 because of an unsettled
claim on the seed grain debt, though repayment of that debt by Saskatchewan
was never made a condition of the Agreement. It is true that the CCF Party
defeated the Liberal Party in Saskatchewan in 1944, but to a constitutional
lawyer no significance can be attributed to this event. Yet even to a con-
stitutional lawyer it would seem that gentlemen’s agreements ought to be
carried out in a gentlemanly way, and that where strict law ends good faith
must continue. This is particularly necessary in a federal system as complex
and delicate as our own, and it does not seem an adequate answer to say, as
did the Arbitration Board appointed to hear the seed grain dispute, that there
was nothing illegal in Ottawa’s behaviour.9 Money promised in the Agreement-
suddenly ceased to be paid, upsetting provincial plans and revealing the
tenuous nature of the legal obligations created.

Because taxation agreements are based on consent and not on constitutional
obligation, it follows that special deals with particular provinces are legally
unassailable. We have no requirement that taxation must be undiscriminatory,
or equal as between the provinces. If national policy requires that wealth
shall be taken from the richer and given to the poorer regions, the manner of

SA.-G. for B.C. v. E. & N. Rly. [1950] A.C. 87.
OThe Board was divided in its opinion: see [1946] W.W.R. p. 257.

McGILL LAW JOURNAL

[Vol. 2

its distribution is a matter of politics and not of law. Hence the abstention of
some provinces does not preclude the possibility of agreements with others,
as past practice makes abundantly clear.

THE SPENDING POWER OF GOVERNMENTS

All public monies that fall into the Consolidated Revenue Funds of the
federal and provincial governments belong to the Crown. The Crown is a
person capable of making gifts or contracts like any other person, to whom-
soever it chooses to benefit. The recipient may be another government, or
private individuals. The only constitutional requirement for Crown gifts is
that they must have the approval of Parliament or legislature. This being
obtained the Prince may distribute his largesse at will. Such gifts, of course,
do not need to be accepted; the donee is always as free to reject as the donor
to offer. Moreover, the Crown may attach conditions to the gift, failure to
observe which will cause its discontinuance. These simple but significant powers
exist in our constitutional law though no mention of them can be found in the
B.N.A. Acts. They derive from doctrines of the Royal Prerogative and the
common law. They operate equally for the Crown in right of provinces as well
as for the Crown in right of the Dominion. It would be as lawful for provinces
to subsidize Ottawa as for Ottawa to subsidize provinces; the only difference
is that Ottawa is obliged by the constitution to pay certain statutory sums.

These rules explain several interesting practices inherent in Canadian
federalism. They explain why no amendment was necessary to the B.N.A. Act
in 1869 when the amount guaranteed to Nova Scotia was increased; if the
federal Crown is obliged to give x dollars to a province, it does not violate
its promise by giving x plus y dollars. It may excite the cupidity of other
provinces by so doing, but that is not a legal matter. So too these rules explain
how it has been possible for Ottawa to set in motion a variety of welfare
projects, such as family allowances and grants to universities, through the
method of the grant in aid. It explains how Canadian Government annuities
were established. And not only Ottawa employs this method. The Province
of Quebec, which has been most insistent on provincial autonomy in education,
does not hesitate to make grants of public money to colleges in other provinces.
According to Mason Wade’ the redoubtable Mercier, as staunch a defender
of Quebec’s rights as the present premier of Quebec, even gave $10,000 to the
University of Toronto after it had suffered in a bad fire. This was indeed a
beau geste. But what is the difference, one may ask, between giving to a
university after a fire and giving annually without regard to conflagrations?
If Ottawa’s gift to Quebec universities is an invasion of Quebec’s rights, why
is not Quebec’s gift to Toronto, or to the University of Ottawa, an invasion
of Ontario’s rights? The true answer is that none of these gifts is an invasion
of anybody’s rights in so far as constitutional law is concerned. Generosity in

19 The French Canadians, p. 428.

No. 1]

TAXATION A GREEMENTS

Canada is not unconstitutional. If the grants are undesirable, it must be for
non-legal reasons.

Making a gift is not the same as making a law. Because one type of govern-
ment alone has jurisdiction over a class of subject under the B.N.A. Act, does
not mean that the other may not make gifts to persons whose activities fall
within that class. A province, for example, may not make laws having extra-
territorial operation, but it may make gifts having such operation. Quebec
made a gift of $35,000.00 for flood relief in Europe in 1953. Gifts from
American Foundations to Canadian universities are not ‘laws in relation to
education’, No more are gifts from the Crown, even though such gifts must be
approved in an Appropriation Act before the payment is lawful. Tying all
this to taxation agreements, it is quite lawful for Ottawa to entice provinces
into agreements by offering to pay them more for surrendering certain taxes
than would be received by them through those taxes. Call it a gift or a “tax
rental”, it is equally within the discretion of the Crown, if Parliament
approves.

THE QUESTION OF PRIORITIES

In the recent debate between Ottawa and Quebec regarding income taxes,
a claim was put forward in high provincial places, and indeed was written
into the preamble of the Quebec statute imposing its income tax,” that the
Canadian constitution recognized provincial priority in the matter of direct
taxation. This part of the statute was repealed after Ottawa agreed to allow
certain deductions for the Quebec taxpayers. What is the law on the point?

If by priority is meant that every time a province enters the income tax
field the federal government must evacuate it, there is obviously no such
priority, As already said, the exclusive provincial jurisdiction over direct
taxation is only for the raising of revenues for provincial purposes; direct
taxation for federal purposes is exclusively a federal power. As was said by
Lord Macmillan in the Forbes case,12 “Both income taxes (federal and
provincial) may co-exist and be enforced without clashing. The Dominion
reaps part of the field of the Manitoba citizen’s income. The Province reaps
another part of it”. But what happens if the poor Manitoba citizen is reaped
right down to his bare stubble? Suppose the taxpayer has not enough money
to pay both taxes, who then is paid first? This is the only case where conflict
between the taxes exists in the legal sense.

To this question the Privy Council has already given the answer. In Silver’s
case, 13 where a bankrupt company owed taxes both to Quebec and to Ottawa,
Viscount Dunedin, while holding that on the statutes before him the two
claims ranked pari passu, went on to say that either under head 21 of 91
(bankruptcy) or under head 3 of 91 (taxation) it would have been competent

112-3 Eliz. 11, cap. 17.
12[1937] A.C. 260.
18[1932] A.C. 514.

McGILL LAW JOURNAL

[Vol. 2

for Ottawa to have made its claim prevail over that of the province if it so
wished:

The two taxations, Dominion and Provincial, can stand side by side without inter-
fering with each other, but as soon as you come to the concomitant privileges of
absolute priority they cannot stand side by side and must clash; consequently the
Dominion must prevail.

This is because of the well-established rule that where there is a concurrent
field of legislation neither the federal nor the provincial laws are ultra vires if
they do not conflict, but once they do the federal law prevails. The only
exception to this rule seems to be in regard to the old age pensions amendment
of 1951. Prof. K. C. Wheare, in his Federal Government, 4 seems to think
that this ruling has destroyed the federal principle in Canada in so far as the
taxing power is concerned. To which my reply is that the Canadian constitution
was never expected to operate on strictly federal principles as the political
scientist understands them; we adopted, for what seemed good reasons, a
constitution leaning toward a strong central authority whose power might
offset in some degree the centrifugal forces which are always present in the
body politic.15 Let it not be forgotten that the first attempt to escape from
Confederation was made by Nova Scotia within eight months of the coming
into force of the B.N.A. Act.

THE SYMBOLISM OF TAXATION AGREEMENTS

The dry bones of constitutional law are not the living flesh of Canadian
politics. The problems involved in taxation agreements reach far beyond the
ground covered in an analysis of legal rules. Yet the problems cannot be under-
stood and no satisfactory solution can be worked out unless they proceed
from an analysis of the legal norms established in the fundamental law.

It is only too apparent that in Canada one great difficulty is to reach agree-
ment on the kind of federal-provincial relationships that the constitutional
rules imply. On many technical points such as have been discussed here, final
decisions of the Privy Council or the Supreme Court of Canada give us an
answer, but on much more fundamental matters the court decisions are silent
or confusing. It is precisely these deeper issues which elevate constitutional
discussion in Canada to the plane of philosophical debate and which intrude
themselves into every aspect of federal-provincial relations.

The point can be illustrated by asking some simple questions. What is the
nature of the BN.A. Act? Is it a statute or a compact, or, as Pare Arrh~s
holds, both a statute and a compact?16 Or is it to be explained by the “theorie
de l’institution” as Edouard Laurent maintained ?17 If it is a compact, between

‘ 43rd ed. pp. 110-114.
151 have expanded this argument in “The Special Nature of Canadian Federalism”,

(1947) C.J.E.P.S. pp. 13 ff. ”
16See La Conf!dgration: Pacte ou Loi, 6ditions de L’Action Nationale, 1949, p. 72.
17See Quelle est la nature de l’acte de 1867f Cahiers de

‘Ecole des Sciences Sociales,

Laval (n.d).

No. 1]

TAXATION AGREEMENTS

whom was it made; between the four original provinces, between all the
provinces and the Dominion, or simply, as the prevalent theory in Quebec
seems to maintain, between races? If it is a compact between races, is it
between the French race and all other races in Canada collectively, or between
French and English, using English in the Quebec sense of meaning anyone
from the British Isles ?18 Again, is the aim of the constitution the retention of
what Lord Atkin calls “the watertight compartments”, 19 or is it rather, as
Lord Sankey once said,20 “to give the central government those high functions
and almost sovereign powers by which uniformity of legislation might be
secured on all questions which were of common concern to all the provinces as
members of a constituent whole ?”

It is unlikely that a single answer will ever be given to these questions by
all Canadians. Each will answer according to his basic philosophical approach
and according to the ends he has in view. In a bicultural country, the back-
grounds, educational systems and political aspirations are too varied to permit
of single explanations of constitutional rules. To someone trained in Dicey’s
Law of the Constitution, the B.N.A. Act is simply a statute to be obeyed by
our courts because of the ancient doctrine of imperial sovereignty. Is it reason-
able to expect so technical a view to be held by a graduate of a classical college
in Quebec? Is be not right when he reminds us that the great central facts of
Canadian life –
the race relationships, the religious guarantees, the biling-
ualism –
cannot be subsumed under narrow legal concepts? Is it surprising
that he finds a continuing difficulty in expressing his French realities in the
terms of English legalities? The Canadian constitution is not even written in
one of the two official languages of this country –

his own.

It is unfortunate for the economists who wish Ottawa to adopt a fiscal
policy based on Keynsian principles, that taxation arrangements have now
become involved in, and perhaps dominated by, Quebec’s insistence on the
recognition of her status and her rights under the Canadian constitution. It is
also unfortunate for the unemployed in Quebec and elsewhere, since battles
over status seldom aid in solving economic problems. As a member of the
Quebec delegation said after the first sessions of the federal-provincial fiscal
conference in April, 1955, “When other provinces come to Ottawa they bring
their problems and leave their rights behind. Quebec brings her rights and
leaves her problems behind”. But few will doubt that Quebec is standing on
very strong ground in stressing the non-economic factors in this debate.
Quebec’s view is based on the theory that the maintenance of Canadian
federalism requires that each province, and particularly Quebec, should be
able to finance its own functions of government out of its own resources;
otherwise it.ceases to have any autonomy worth the name. This is claimed as a
1 8The only race mentioned by name in the B.N.A. Act is the Indian race, and Indians

were made wards of Ottawa.

19[1937] A.C. at p. 354.
20[1932] A.C. at p. 70.

McGILL LAW JOURNAL

[Vol. 2

right, not as a privilege or concession. Since taxation agreements as hitherto
devised seem to imply an abandonment of this right, their rejection is an act of
honour. They become mixed up with feelings of status and prestige, and cease
to be merely practical devices for solving common problems. And since
Quebec’s income tax of 1954 brought these issues vividly to the Quebec public,
the income tax itself became, in a sense, a symbol of cultural defence. This
explains why there has been so much insistence over deductions for an income
tax in Quebec, whereas a far wider group of Quebec taxpayers –
including
the lowest paid workers –
pay a double and sometimes a triple sales tax
without any sense that their culture is at stake. Yet why, one may ask, is an
income tax more honourable than a sales tax? It affects far fewer people.

The currents of constitutional thinking in Quebec suggest that to-day the
identification of the government of Quebec with the whole French-Canadian
race is greater than ever before. This identification once assumed as a major
premiss, a number of new concepts about Canadian federalism seem to follow.
Canada is seen not just as one central government and ten provincial govern-
ments, Quebec being merely one of the ten: rather is it looked upon as com-
posed of two races, equal in status, one of which speaks through the govern-
ment of Quebec and the other through Ottawa. Hence Quebec on this view is
one of two governments. The notion of Canada as a dyarchy, or a dual
monarchy, is implicit in much of the contemporary discussion on federal-
provincial relations.

Fiscal policy in Canada is thus enmeshed in minority rights. When financial
arrangements achieve the importance and magnitude of current tax agree-
ments this is scarcely surprising. For the inner conflict in all federal states
between growing welfare responsibilities resting on the local governments,
and new fiscal responsibilities for promoting overall economic welfare resting
on the central government, is difficult enough to resolve even in a homogeneous
society. It assumes added complexities in a bicultural society. With us taxa-
tion agreements must be understood as achieving two objectives simultan-
eously: Quebec’s autonomy, as well as economic stability. Autonomy for
English-speaking provinces is, of course, also a serious factor, but without
minority complications. This is no criticism of past agreements; they may
have been the best that could be devised. They were not so understood in
Quebec, however, and too little attention was paid to the necessity of securing
that widespread acceptance of the aims and objectives of the agreements,
which is necessary if so significant a change in older constitutional relation-
ships is to iest on some adequate degree of popular consent. In this issue two
powerful ideas are contending for recognition –
provincial self-government
and federal responsibility for overall economic stability. Provincial resistance
creates a countervailing power to balance federal control. Too much resistance
could create economic chaos, too little might endanger federalism itself.
Finding the acceptable mean is the art of Canadian fiscal policy.

in this issue The Law Cannot Stand Still

related content