Federation of Law Societies: Towards a Deeper Understanding of the Principles of Fundamental Justice
Bibliographic record
Abstract
In Attorney General of Canada v. Federation of Law Societies of Canada, Cromwell J., writing for the majority, recognized a new principle of fundamental justice under section 7: a lawyer’s duty of commitment to the client’s cause. Discussion surrounding Federation of Law Societies has generally focused on the importance of solicitor-client privilege and of its significance for the independence of the bar. Relatively less consideration, however, has been given to how this case contributes to section 7 Charter jurisprudence more broadly. This paper seeks to fill this gap by exploring how Justice Cromwell’s reasons in Federation of Law Societies develop our understanding of the principles of fundamental justice. Specifically, this paper considers four insights that may be drawn from Cromwell J.’s analysis of the lawyer’s commitment to the client’s cause as a principle of fundamental justice explores, namely: (i) a principle of fundamental justice may be sub-divided into different aspects or variations of the same principle; (ii) solicitor-client privilege is not the only aspect of a lawyer-client relationship that has a constitutional dimension; (iii) this principle is distinctive as compared to previously-recognized ones, in that it is justified by engaging with a non-state actor’s role in the architecture of the legal system; and (iv) this one evades being classified as either a substantive or procedural principle.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.019 | 0.011 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.002 |
| Bibliometrics | 0.003 | 0.002 |
| Science and technology studies | 0.014 | 0.047 |
| Scholarly communication | 0.015 | 0.021 |
| Open science | 0.003 | 0.009 |
| Research integrity | 0.013 | 0.014 |
| Insufficient payload (model declined to judge) | 0.002 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".