 Since Alberta and Prince Edward Island did not have such commissions, while Manitoba did but did not consult its commission, their actions regarding remuneration were deemed invalid.The decision created certain challenges, and the governments of Alberta, Manitoba and Prince Edward Island had to approach the Court again for a solution.Since section 11(d) of the Canadian Charter of Rights and Freedoms guarantees a right to be tried before an independent tribunal, and in 1997 the Court decided the Provincial Courts of these three provinces were not independent, the decision threw many criminal law cases into question.