Rabbi Solomon Frank, a founding member of the Canadian Jewish Congress (CJC), advocated for the religious freedom of Jehovah's Witnesses, criticizing Quebec's government of being "anti-democratic.
"[1] In 1953, the case of Saumur v Quebec (City of) (1953) 25 CR 299 (in which a Jehovah's Witness challenged a Quebec City bylaw prohibiting public distribution of literature without a permit) left the question of religious freedom undecided as: "both Parliament and the provinces could validly limit freedom of worship providing they did so in the course of legislating on some other subject which lay within their respective powers.
"[2] This decision was part of a series of cases the Supreme Court dealt with concerning the rights of Jehovah's Witnesses under the Duplessis government of Quebec.
The court held that in 1946 Maurice Duplessis, both Premier and Attorney General of Quebec, had overstepped his authority by ordering the manager of the Liquor Commission to revoke the liquor licence of Frank Roncarelli, a Montreal restaurant owner and Jehovah's Witness who was an outspoken critic of the Roman Catholic Church in Quebec.
This was cited by Kent Roach, writing for the University of Toronto Law Journal, as an example that "courts were more generous in accessing damages than they are today under the Charter".