R v Coote

R v Coote
R v Coote was the first decision of the Judicial Committee interpreting the British North America Act, 1867
Court	Judicial Committee of the Privy Council
Full case name	Our Sovereign Lady the Queen v Edward Coote
Decided	March 18, 1873
Citations	(1873) LR 4 PC 599 [1873] UKPC 26 (1873) 9 Moo PC NS 426 17 ER 587
Case history
Appealed from	Quebec Court of Queen's Bench
Court membership
Judges sitting	Sir James W. Colvile Sir Barnes Peacock Lord Justice Mellish Sir Montague Smith Sir Robert P. Collier
Case opinions
Provincial statute authorising inquiries by fire commissioners within provincial authority. Statements could be used in criminal prosecution.
Decision by	Sir Robert P. Collier
Keywords
Provincial inquiry power; Admissibility of depositions

R v Coote is a Canadian constitutional law decision in 1873 dealing with the powers of the provinces under the British North America Act, 1867 (now the Constitution Act, 1867).^[1] The point in issue was whether Quebec had the constitutional authority to create a mandatory inquiry power for provincial fire commissioners.

The case was ultimately decided by the Judicial Committee of the Privy Council, at that time the court of last resort for Canada within the British Empire.^[2] It was the first decision by the Judicial Committee analysing the division of powers under the Constitution of Canada.

The Judicial Committee held that the mandatory inquiry power was within provincial authority. The Judicial Committee also held that evidence given by an individual in response to a mandatory inquiry could later be used as evidence against that individual in a criminal prosecution for arson.^[3][4]