The "Act" begins with a preamble declaring that the three provinces New Brunswick, Nova Scotia and the Province of Canada (which would become Ontario and Quebec) have requested to form "one Dominion...with a Constitution similar in Principle to that of the United Kingdom". This description of the Constitution has proven important in its interpretation. As Peter Hogg wrote in "Constitutional Law of Canada", some have argued that, since the United Kingdom had some freedom of expression in 1867, the preamble extended this right to Canada even before the enactment of the "Canadian Charter of Rights and Freedoms" in 1982; this was a supposed basis for the Implied Bill of Rights. In "New Brunswick Broadcasting Co. v. Nova Scotia", the leading Canadian case on parliamentary privilege, the Supreme Court of Canada grounded its 1993 decision on the preamble. Moreover, since the UK had a tradition of judicial independence, the Supreme Court ruled in the "Provincial Judges Reference" of 1997 that the preamble shows judicial independence in Canada is constitutionally guaranteed. Political scientist Rand Dyck has criticized the preamble, saying it is "seriously out of date". He claims the "Act" "lacks an inspirational introduction".