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54. These two cases, it is true, related to interprovincial rather than international situations, but it is clear from the rejection in Trudel of the reasoning in R. v. Selkirk that the court attached no importance to this distinction. In any event, the reasoning in Trudel was approved by a panel of five members of the Ontario Court of Appeal, consisting of Gale C.J.O. and McGillivray, Kelly, Laskin (later C.J.C.) and Brooke JJ.A., in 1970 in the important case of Re Chapman, supra. While that court refrained from saying that the situs of an offence can never be determined on the basis of notions derived from contract or agency, it concluded that the court in Selkirk had taken too limited a view. "Since the credit card did reach the accused in Toronto", it noted at p. 53, "there was factual realization of the fraudulent scheme put into motion by the accused, and hence, a sound basis for concluding that if an offence had been committed it was committed in Toronto".
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