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Record W4416290420 · doi:10.29173/alr2816

The Extinguishment of Aboriginal Rights and the James Bay Agreement: The Condition 14 Test

2025· article· W4416290420 on OpenAlexvenueaboutno aff
Ghislain Otis

Bibliographic record

VenueAlberta Law Review · 2025
Typearticle
Language
FieldSocial Sciences
TopicIndigenous Peoples' Rights and Law
Canadian institutionsnot available
Fundersnot available
KeywordsExtinguishmentIndigenousConstitutionParliamentNegotiationOrder (exchange)Test (biology)

Abstract

fetched live from OpenAlex

In 1977, an Act of the Parliament of Canada approved the James Bay and Northern Québec Agreement signed by the Crown and the Cree and the Inuit of Quebec. The Act purported to extinguish the Aboriginal title and interests of “all Indians and all Inuit” in and to the territory covered by the Agreement, thus extending the extinguishment clause to the land claims of Aboriginal peoples that were not parties to the Agreement. This purported unilateral extinguishment clause was met with immediate resistance from various non-signatory Indigenous groups who claimed that they were not properly consulted and that their Aboriginal title was unjustly extinguished. This article examines the validity of this claim, particularly whether, prior to the enactment of section 35 of the Constitution Act, 1982, there were any constitutional constraints on Parliament’s ability to unilaterally extinguish the rights of Indigenous peoples. The article argues that the 1870 Order in Council admitting Rupert’s Land into Canada, in particular Condition 14 of the Order, provides such constraints and thus precludes the unilateral extinguishment of the Aboriginal title of the non-signatory people. This article ultimately calls for negotiation and reconciliation among all parties involved in order to resolve the outstanding land claims and ensure the equitable recognition of Aboriginal rights.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame machine prediction

Teacher imitation

Not 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.

metaresearch head score (Codex)0.025
metaresearch head score (Gemma)0.039
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.846
Threshold uncertainty score0.306

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0250.039
Meta-epidemiology (narrow)0.0000.001
Meta-epidemiology (broad)0.0010.001
Bibliometrics0.0010.001
Science and technology studies0.0070.034
Scholarly communication0.0080.008
Open science0.0030.005
Research integrity0.0100.012
Insufficient payload (model declined to judge)0.0090.001

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.

Opus teacher head0.006
GPT teacher head0.297
Teacher spread0.291 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designNot applicable
Domainnot available
GenreEmpirical

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".

Quick stats

Citations0
Published2025
Admission routes2
Has abstractyes

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