 The Court decided it should delay the requirement of commissions until September 18, 1998, one year after the 1997 Reference.In a subsequent judicial independence case, "Mackin v. New Brunswick" (2002), the Supreme Court found a government action unconstitutional for not following the "Provincial Judges Reference", although the action predated the reference.The action also came before September 18, 1998, the day the commission requirement became effective according to "Re Remuneration of Judges (No.