 Since the Supreme Court, in 1997, found independent committees were needed to help determine judicial salaries, the Court now had to address challenges regarding the creation of such committees.In the "Provincial Judges Reference" of 1997, the Court found that Alberta, Manitoba and Prince Edward Island's remuneration of Provincial Court judges was unconstitutional, since it breached a requirement for judicial independence.The Court said that independent salary commissions were needed to help recommend salaries, and governments could deviate from these recommendations only with rational reasons.