Later, the Court would add in "R. v. Goltz" (1991) and "R. v. Morrisey" (2000) that how the individual would be impacted by the punishment in practise, the objectives of the punishment, whether other kinds of punishments could be used instead, and how other types of criminals are punished could be relevant to a section 12 test. Still, the test is not strict but rather deferential to the government. In "Steele v. Mountain Institution" (1990), Justice Cory wrote for the Court that a judicial discovery of a cruel and unusual punishment should be "rare and unique". The Parliament of Canada's ability to judge the appropriateness of various punishments is not absolute, but courts are generally encouraged to exercise restraint in correcting Parliament.