the

Charter to

Canadian judges on the other hand,

touchstone against which provide the widely expressed rights and freedoms must be limited:

have section 1 of

the

"The Canadian Charter of Rights

of Rights and Freedoms guarantees the rights and freedoms set out in it such

limits reasonable as can be demonstrably

subject prescribed

only

to by law

justified in a free and democratic society.

H

This is, by now, a common formula. Around it has developed a

courts have

well

worked

jurisprudence.

The Canadian

developed

whether

a

" form

and proportionality"

test

to

determine

limits

on

the

rights

and freedoms

57

suggested

guaranteed by the Charter may be upheld.

58

Once a court has declared what the basic rights are and

what they require, there must be a convention of obedience

which follows. That convention exists in the United States,

Canada and other countries.

In developing countries of

the Commonwealth obedience on the part of authority is not

always automatic. Thus,

in Zimbabwe recently, tension was

between the High Court reported

Government.

and the Executive

The Court made declarations under

Rights

provisions

of the

Constitution

under the Basic

relating

to

the

treatment of three prisoners in conditions which members of

59

At last the Court took the pains themselves to inspect.

report, the Executive Government had declined to follow the

down by the High régime laid

the High Court, designed to secure

conformity

in

their treatment with the

guarantee against cruel and unusual punishment.

for contempt were reportedly planned.

constitutional

Proceedings

But courts have no armies to enforce their orders. A

few sheriffs and bailiffs

are all they can call upon,

in

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