Beauregard's suggestion that judges should not have to contribute to pensions owed partly to section 92(14) of the Constitution Act, 1867, which assigned the administration of justice to the provincial governments. This suggested the federal and provincial governments would have to agree to the creation of a pension to which judges must contribute. Dickson refuted this argument by saying the general effect of section 92(14) is limited by other more specific parts of the Constitution, in this case, section 100. Another interpretation of section 100 was that the type of pensions it mentioned was the kind that existed at the time of Canadian Confederation, i.e. pensions to which judges did not contribute. Moreover, the section's requirement that Parliament provides the pension could be taken as meaning Parliament alone; the section did not say judges along with Parliament had the responsibility. Dickson rejected the idea that the type of pension had to be the same as it was at Confederation in 1867 because the Constitution is meant to adapt to changing circumstances. This was the living tree doctrine. As for the notion that Parliament alone must pay for the pension, Dickson replied under section 100, Parliament must pay a pension, but section 100 did not say what percentage of a total pension.