

Bill C-84: A Step in the Right Direction
Bill C-841 was introduced by the Liberal government in 2018. Aside from expanding the scope of animal fighting offences, it also sought to finally define bestiality statutorily. As of June 2019, the proposed definition was codified in section 160(7) of the Criminal Code. To adequately grasp the impact of Bill C-84, regard must be had to the history of bestiality in Canada.


The SCC and DLW: An Example of Judicial Restraint in Difficult Circumstances?
Was the Supreme Court of Canada’s (“SCC”) decision in R v D.L.W. (DLW) appropriate? In deciding DLW the SCC determined the definition of bestiality within s. 160 of the Criminal Code of Canada. The definition may be unsatisfactory and unsavory for many given the circumstances of the case. The cases’ dissent upon each level of appeal is evidence of that reality. A summary of the facts of the case followed by a brief analysis of the courts’ conclusion will be given.




