The Court noted the previous landmark judicial independence case, "Valente v. The Queen" (1985), established that independence belongs both to a judge and to a court as a whole. The Court now explained that this interpretation of independence was appropriate considering the roles of courts. While one role is to resolve conflicts, another was to guard the Constitution and constitutional values of the rule of law and fundamental justice. Thus, judicial independence is the "lifeblood of constitutionalism in democratic societies." The Court then explained judicial independence in Canada has more than one basis. One was the existence of federalism, as courts were needed to clarify jurisdictions, especially since Parliament no longer used its power to decide such questions, disallowance. The existence of the Canadian Charter of Rights and Freedoms, since 1982, also implies judicial independence is necessary to guard rights. Another source of judicial independence could be found in the preamble to the Constitution Act, 1867. It stated the Constitution of Canada should be "similar in Principle" to the Constitution of the United Kingdom, and judicial independence was a constitutional principle in the United Kingdom. Sections 96 to 100 of the Constitution Act, 1867 were another source.