706 THE FEDERATIONS AND THE UNION [rant Iv 
vires, citing Citizens’ Insurance Co. of Canada v. Parsons! and 
Colonial Building and Investment Association v. Atltorney- 
General of Quebec? He admitted that the company could 
conclude contracts outside (e.g. buy machinery), but only as 
ancillary to provincial operations. 
In this case, besides the particular points at issue, the 
following general questions were asked :— 
1. Is every charter issued by virtue of provincial legislation 
to be read subject to a constitutional limitation that it is 
prohibited to the company to carry on business beyond the 
limits of the province within which it is incorporated ? 
2. Can an insurance company incorporated by letters 
patent issued under the authority of a Provincial Act carry 
on extra-provincial or universal insurance business, i.e. make 
contracts and insure property outside of the province, or 
make contracts within to insure property situate beyond ? 
3. Has a province power to prohibit or impose conditions 
and restrictions upon extra-provincial insurance companies 
which transact business within its limits ? 
4. Has Parliament authority to authorize the Governor in 
Council to permit a company locally incorporated to transact 
business throughout the Dominion or in foreign countries ? 
The judgement of the Court on the case was substantially 
in favour of the provinces, except that the last question 
was not answered by the majority of the Supreme Court. 
The Canadian Government have now brought before the 
Supreme Court the whole question of the powers of the 
provinces and the Dominion regarding companies on a 
special reference by the Governor-General in Council, which 
the Supreme Court has decided it has authority to hear. But 
from the preliminary point an appeal has been brought to 
the Crown in Council. The difficulty is brought to a head 
by the British Columbia Act ¢. 7 of 1910,® which requires all 
foreign companies either to be registered or take out a licence 
to act, and which forbids the recovery by such companies of 
debts within the province if not so registered and licensed. 
£7 App. Cas. 96. 2 9 App. Cas. 157. 
See also Manitoba Acts 1911, ce. 9 and 10.