Cory J.
Factual Background
Relevant Statutory Provisions
2. In this Act,
. . .
“traffic” means
(a) to manufacture, sell, give, administer, transport, send, deliver or distribute, or
(b) to offer to do anything referred to in paragraph (a)
otherwise than under the authority of this Act or the regulations.
3. (1) Except as authorized by this Act or the regulations, no person shall have a narcotic in his possession.
. . .
4. (1) No person shall traffic in a narcotic or any substance represented or held out by the person to be a narcotic.
(2) No person shall have in his possession any narcotic for the purpose of trafficking.
. . .
8. (1) In any prosecution for a contravention of subsection 4(2), if the accused does not plead guilty, the trial shall proceed as if it were a prosecution for an offence under section 3.
(2) After the close of the case for the prosecution pursuant to subsection (1) and after the accused has had an opportunity to make full answer and defence, the court shall make a finding as to whether or not the accused contravened subsection 3(1) and, if the court finds that the accused did not contravene subsection 3(1), the accused shall be acquitted but, if the court finds that the accused contravened subsection 3(1), the accused shall be given an opportunity of establishing that he was not in possession of the narcotic for the purpose of trafficking and, thereafter, the prosecutor shall be given an opportunity of adducing evidence to establish the contrary.
Criminal Code , R.S.C., 1985, c. C‑46 :
21. (1) Every one is a party to an offence who
(a) actually commits it;
(b) does or omits to do anything for the purpose of aiding any person to commit it; or
(c) abets any person in committing it.
Decisions Below
Saskatchewan Court of Queen’s Bench
Saskatchewan Court of Appeal (1996), 144 Sask. R. 241
Analysis
Aiding and Abetting
Liability of an Agent for the Purchaser
. . . since possession of a narcotic is an offence, and there is an onus on an accused who pleads not guilty to a charge under s. 4(2) to establish that his possession was not for the purpose of trafficking (see s. 8 of the Act), it would, in my opinion, be incongruous to turn a mere purchaser into a trafficker by using s. 21 of the Criminal Code to supply the want of definition.
He went on to conclude that it is implicit from the reasons of Dickson J. (as he then was) for the majority in Poitras that he too accepted the proposition that the purchaser of a narcotic does not by that act alone engage in trafficking. I agree with that conclusion.
If the purchaser who has encouraged the sale of a narcotic drug to himself cannot be convicted of trafficking, it must be because the Narcotic Control Act manifests a legislative intention that a mere purchaser does not incur liability in respect of the offence of trafficking committed by the seller.
A similar observation is made in the helpful text Criminal Pleadings & Practice in Canada, supra, at p. 15‑9, para. 15:2090 (release May 1997):
It seems that a purchaser of drugs, although factually aiding or abetting the seller, does not legally aid or abet the seller, i.e., the trafficker of drugs, since the purchaser commits the separate offence (when purchasing the drugs) of simple possession of the drugs or possession of the drugs for the purpose of trafficking. [Emphasis in original.]
It was argued on behalf of the appellant that the words “to buy” do not appear in the definition of “trafficking” under the Narcotic Control Act; therefore a mere purchaser does not traffic and an agent for the purchaser comes under the same protective umbrella. I do not agree. One cannot apply the civil law of “agency” in this context. “Agency” does not serve to make non‑criminal an act which would otherwise be attended by criminal consequences. Even if the appellant could be said to be the “agent” of Constable Arsenault for the purposes of civil responsibility, his acts may, none the less, amount to trafficking in narcotics or aiding in such trafficking.
Thus the majority was prepared to accept that someone who acts on behalf of a purchaser can be found to have assisted in the trafficking of narcotics.
Application of the Principle to the Case at Bar
One can speak of an actor doing something “on purpose” (as opposed to by accident) thereby equating purpose with “immediate intention”. The term is also used, however, to indicate the ultimate ends an actor seeks to achieve, which imports the idea of “desire” into the definition.
After reviewing the pertinent case law and academic commentary, Lamer C.J. concluded that the former definition must have been that intended by Parliament when it drafted s. 21(1)(b) of the Code. For the purposes of this section, he said, “purpose” should be equated with “intention” and not “desire”. In other words, in order to satisfy the purpose requirement under s. 21(1)(b), the Crown is required to prove only that the accused intended the consequences that flowed from his or her aid to the principal offender, and need not show that he or she desired or approved of the consequences.
Jurisdiction of the Court of Appeal
The Appellant’s Liability as a Principal
Disposition
Cases cited
- 144 Sask.R. 241 144 Sask.R. 241 ¶ 23
- R. v. Meston 28 C.C.C. (2d) 497 pp 503 ¶ 26, ¶ 28
- Criminal Law Criminal Law, supra, at p. 272 p. 272 ¶ 26
- Canada Canada, supra, at p. 15 p. 15 ¶ 26, ¶ 30
- Poitras v. R. item-5208-1973-06-29 ¶ 29, ¶ 33, ¶ 34
- R. v. Oakes 17550-1986-02-28 ¶ 30
- 507 of Meston 507 of Meston, supra ¶ 30
- of Poitras of Poitras, supra ¶ 33
- R. v. Hibbert 23815-1995-07-20 ¶ 37
- R. v. Curran 38 C.C.C. (2d) 151 ¶ 38
- R. v. Morin 22530-1992-01-30 p 294 ¶ 40
Statutes and regulations cited
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Unresolved citations