Valin v Langlois

Valin v Langlois
Valin v Langlois concerned a disputed election to the Parliament of Canada in 1878
Court	Supreme Court of Canada
Full case name	Controverted Election of the County of Montmorency: P.V. Valin and Jean Langlois
Decided	October 28, 1879
Citations	(1879), 3 SCR 1
Case history
Appealed from	Langlois v Valin (Montmorency Case) (1879), 5 QLR 1 (Que. SC)
Appealed to	Judicial Committee of the Privy Council
Subsequent actions	Judicial Committee dismissed application for leave to appeal; Superior Court declared seat declared vacant
Court membership
Judges sitting	Ritchie C.J. Fournier Henry Taschereau Gwynne
Keywords
Constitutional law; federal election law; superior court jurisdiction

Valin v Langlois
The Judicial Committee declined leave to appeal from the Supreme Court of Canada
Court	Judicial Committee of the Privy Council
Full case name	Pierre Vincent Valin v Jean Langlois
Decided	December 13, 1879
Citation	(1879-80) 5 App. Cas. 115, [1879] UKPC 68 (PC)
Case history
Appealed from	Valin v Langlois (1879), 3 SCR 1
Subsequent action	Seat declared vacant by the Superior Court
Court membership
Judges sitting	Lord Selborne Sir James W. Colville Sir Barnes Peacock Sir Montague E. Smith Sir Robert P. Collier
Case opinions
Leave to appeal denied
Decision by	Lord Selbourne
Keywords
Constitutional law; federal elections; jurisdiction of superior courts

Valin v Langlois is a Canadian constitutional law decision from the Supreme Court of Canada, concerning the jurisdiction of the federal Parliament over federal elections, as well as the constitutional jurisdiction of the provincial superior courts. The Court held that the Parliament of Canada has sole jurisdiction to enact laws regulating federal elections, including provisions for controverted elections. The Court also held that the provincial superior courts have general jurisdiction over questions of federal and provincial law, and that Parliament could give provincial courts jurisdiction to apply federal laws.

The case arose from a controverted federal election in 1878, in the Quebec riding of Montmorency. Pierre-Vincent Valin was declared the successful candidate, but his election was challenged by his opponent, Jean Langlois, in the Superior Court of Quebec under the Dominion Controverted Elections Act, 1874.

On appeal, the Supreme Court of Canada upheld the constitutionality of the law. Valin then tried to appeal to the Judicial Committee of the Privy Council, at that time the court of last resort for Canada within the British Empire. The Judicial Committee denied leave to appeal, leaving the Supreme Court decision as the governing statement of the law.

The Supreme Court of Canada continues to cite its decision in Valin v Langlois as the foundational case with respect to the jurisdiction of provincial superior courts, as well as with regard to Parliament's jurisdiction over federal elections. It is also cited for this purpose in texts on Canadian constitutional law.