708 THE FEDERATIONS AND THE UNION [PART IV 
purposes, and companies not rarely, to avoid tedious conflicts 
of jurisdiction, incorporate themselves both federally and 
provincially, especially if they desire navigation privileges, 
or the power to bridge over a navigable stream, for which 
they must, in any case, have parliamentary authority! In 
one case at least the Dominion has incorporated a company 
with a purely provincial object, viz. the Act incorporating 
the Anticosti Company, which Ritchie C.J. declared in 
Forsyth v. Bury? to be clearly ulira vires. But a company 
incorporated by the Dominion may de facto confine itself 
legally to one province.? 
The provinces have on several occasions set up chartered 
corporations, a curious name for a body merely incorporated 
by Act and not by charter, but there is no ground on which 
exception could be taken to the Acts. On the other hand, 
an Ontario Act of 1908 regarding the Chartered Accountants’ 
Corporation of Ontario was disallowed in 1909, because it 
forbade any resident member of the Chartered Institute of 
the United Kingdom from describing himself as a chartered 
accountant while within the limits of the province. Ontario 
in 1910 re-enacted this Act (c. 79), which was disallowed, and 
again in 1911 (c. 48), also presumably to be disallowed, and 
Alberta in 1910 (c. 43) has thus legislated. 
The supremacy of the Dominion legislation over provincial 
legislation as to company incorporation when both are valid 
was asserted in the case of La Compagnie hydraulique de 
St. Francois v. Continental Heat and Light Company.* In 
1 Cf. Bourinot, Parliamentary Procedure and Practice,” p. 680 ; Provincial 
Legislation, 1867-95, pp. 379, 1118; re Brandon Bridge, (1884) 2 M. R. 14; 
Dominion Act 45 Viet. c. 37; House of Commons Debates, 1910-1, pp. 7818 seq. 
2 (1888) 15 S. C. R. 543, at v. 549. See Strong J.. at ». 551: contra, 
Gwynne J. 
* Lefroy, op. cit., p. 636, note 2. In 1881 the Bell Telephone Co. was 
held by the Quebec Courts to have no right to operate in the province under 
the Dominion Act 43 Vict. c. 67, and local Acts were passed for its benefit 
there in 1882; in New Brunswick, Nova Scotia, and Ontario in 1882; and 
in the same year the Dominion Parliament declared it a work for the general 
advantage of Canada. But the Quebec decision was, no doubt, wrong. 
4 [1909] A. C. 194, Cf, Hull Electric Co. v, Ottawa Electric Co., [1902] 
A, C. 237.