In Supreme Court of Canada case of R. v. Brown, 2022 SCC 18, the Supreme Court of Canada concluded that: O a. s. 33.1 of the Criminal Code infringed ss. 7 and 11(d) of the Charter and the infringements were not justified under s. 1 of the Charter. O b. S. 33.1 of the Criminal Code infringed ss. 7 and 15 of the Charter. O c. Section 33.1 of the Criminal Code should be declared constitutional as it is consistent with s. 52(1) of the Constitution Act, 1982. O d. The judgement of the Alberta Court of Appeal should be upheld