The majority determined that the "Patent Act", in its current form, is "ill-equipped to deal appropriately with higher life forms as patentable subject matter" since biological life forms are living, capable of self-replication, incredibly complex, incapable of full description, and can contain important characteristics having nothing to do with the invention. Justice Bastarache identified some of the serious issues surrounding the patentability of higher life forms including: the agricultural impact on farmers who wish to save and reuse seeds, the rights of the "innocent bystander," who may come into possession of a patented organism by virtue of its ability to self-replicate and thus be subject to an infringement action, deterrence of biomedical research and innovation, and the potential for the commodification of human life, tissues and organs.