The majority used the fact that Parliament enacted the "Plant Breeders’ Rights Act" in the wake of the Supreme Court's decision in Pioneer Hi-Bred Ltd. v. Commissioner of Patents to bolster their view that Parliament did not believe the Patent Act was tailored to include higher life forms. Bastarache J. stated that since Parliament enacted specialized legislation to deal with the issues surrounding crossbred plants, a subset of higher life forms, had they wished to extend patentability to other higher life forms, they would have likely done so at the time.