The Supreme Court held that the covenant was not enforceable on the basis that it was too vague, and that restrictive covenants on land had to be related to land use, not the personal characteristics of the owner. In 1938 there was a development in judicial protection of rights. The government of the province of Alberta had passed a series of laws to implement its social credit platform, and had come under heavy media criticism. In response, the Legislature enacted the "Accurate News and Information Act", which would give the government the power to direct media's coverage of the government. The federal government referred several of the Alberta bills to the Supreme Court for a reference opinion. Three of the six members of the Court found that public comment on the government, and freedom of the press, are so important to a democracy that there is an implied bill of rights in Canada's Constitution, to protect those values. The Court suggested that only the federal Parliament could have the power to impinge on political rights protected by the implied bill of rights. The "Accurate News and Information Act" was therefore unconstitutional. The Supreme Court has not, however, used the "implied bill of rights" in very many subsequent cases. The events leading up to World War II, and the genocidal practices of the Nazi government of Germany, had a major effect on the protection of human rights in Canada. Tommy Douglas, at that time a Member of Parliament from Saskatchewan, was in Europe in 1936 and witnessed the Nuremberg Rally of that year, which had a significant effect on him. When he was elected Premier of Saskatchewan, one of his first goals was to entrench human rights in Canada's constitution. At the 1945 Dominion-Provincial Conference he proposed adding a bill of rights to the "British North America Act, 1867", but was not able to gain support for the proposal. Instead, in 1947, the Government of Saskatchewan introduced the Saskatchewan Bill of Rights, the first bill of rights in the Commonwealth since the English Bill of Rights of 1689. The "Saskatchewan Bill of Rights" provided significant protections for fundamental freedoms:   John Diefenbaker, also from Saskatchewan, was another early proponent of protecting human rights in Canada. He wrote a first draft of a bill of rights as a young lawyer in the 1920s. Elected a Member of Parliament in 1940, he regularly introduced a motion each year from 1946 onwards, calling for Parliament to enact a bill of rights at the federal level. He was concerned that there be a guarantee of equality for all Canadians, not just those who had English or French heritage.