Joel Skapinker was a citizen of South Africa residing in Canada who applied to the Ontario bar to practice law.

Skapinker has brought an application to have the provision of the Act requiring Canadian citizenship be held inoperative on the basis that it violated section 6(2)(b) of the Charter.

The unanimous Court held that Skapinker's rights were not violated by the Law Society Act.

He noted several factors that must be considered: In the end Estey finds that section 6 "does not establish a separate and distinct right to work divorced from the mobility provisions in which it is found.

Estey, however, added that his interpretation has been intentionally cautious due to the newness of the Charter and that there may warrant further expansion of the right in the future.