Multiple Access Ltd v McCutcheon[2] is a leading constitutional decision of the Supreme Court of Canada on the resolution of overlapping federal and provincial laws under the doctrine of double aspect.

Multiple Access, a company incorporated under the Canada Corporations Act[3] made an offer to acquire the broadcasting assets of Canadian Marconi Limited, which was accepted.

If the federal and provincial provisions are virtually identical, are directed to achieving the same policy, and create the same rights and obligations, the duplication attracts the doctrine of paramountcy.

“To put the same point in another way, our community life — social, economic, political, and cultural — is very complex and will not fit neatly into any scheme of categories or classes without considerable overlap and ambiguity occurring.

There are inevitable difficulties arising from this that we must live with so long as we have a federal constitution”[5] Dickson examined the Securities Act using the Lederman approach of judicial review, which states: But if the contrast between the relative importance of the two features is not so sharp, what then?

Mere duplication without actual conflict or contradiction is not sufficient to invoke the doctrine of paramountcy and render otherwise valid provincial legislation inoperative.