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It is apparent that legislative history may be admissible for the more general purpose of showing the mischief Parliament was attempting to remedy with the legislation: Toronto Railway Co. v. The Queen (1894), 4 Ex. C.R. 262, at pp. 270‑71; Lyons v. The Queen, [1984] 2 S.C.R. 633, at pp. 683‑84. Additionally, more flexible rules apply in the admission of legislative history in constitutional cases. In those cases the legislative history will not be used to interpret the enactments themselves, but to appreciate their constitutional validity: Reference re Anti‑Inflation Act, [1976] 2 S.C.R. 373; Re Residential Tenancies Act, 1979, [1981] 1 S.C.R. 714; Schneider v. The Queen, [1982] 2 S.C.R. 112; Reference re Upper Churchill Water Rights Reversion Act, [1984] 1 S.C.R. 297; Bell Canada v. Quebec (Commission de la santé et de la sécurité du travail), [1988] 1 S.C.R. 749; R. v. Edwards Books and Art Ltd., [1986] 2 S.C.R. 713; PSAC v. Canada, [1987] 1 S.C.R. 424; and R. v. Whyte, [1988] 2 S.C.R. 3. Legislative history is also admissible in Charter cases to help interpret its provisions: Re B.C. Motor Vehicle Act, [1985] 2 S.C.R. 486, at pp. 506‑9.
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