Fort Frances Pulp and Paper v Manitoba Free Press[1] is a famous decision on the Canadian Constitution by the Judicial Committee of the Privy Council on the "emergency doctrine" of the peace, order and good government power in the British North America Act, 1867.

After the war had ended, the controls were continued in certain key sectors, including newsprint, under an order in council made on 20 December 1919.

The Manitoba Free Press brought an action against Fort Frances in the Supreme Court of Ontario to recover the specified amount.

...very clear evidence that the crisis has wholly passed away would be required to justify the judiciary, even when the question raised was one of ultra vires which it had to decide, in overruling the decision of the Government that exceptional measures were still requisite.

•...it does not follow that in a very different case, such as that of sudden danger to social order arising from the outbreak of a great war, the Parliament of the Dominion cannot act under other powers which may well be implied in the constitution.