 This was allowed since there was no court besides their own that could hear the case.Lamer also concluded the doctrine was used, albeit not overtly, in "Beauregard v. Canada" (1986), since the Supreme Court had to consider its own independence, as well as that of other Canadian courts.However, the Court in 1998 cited "Laws v Australian Broadcasting Tribunal", a decision by the High Court of Australia, to say the doctrine was limited.