Unlike the "Canadian Charter of Rights and Freedoms", which was added to the Constitution of Canada in 1982, the Bill of Rights is not a constitutional instrument but rather an ordinary statute. Still, the "Canadian Bill of Rights" remains in effect, and its guarantee of the "determination" of one's "rights and obligations" through fundamental justice is not precisely duplicated in the Charter. While the term "fundamental justice" "does" appear in section 7 of the Charter, this is to limit the rights to life, liberty and security of the person. Hence, in the 1985 Supreme Court of Canada case "Singh v. Minister of Employment and Immigration", half of the Court found section 2(e) of the Bill of Rights still has a role to play in Canadian law, and they used it to find in favour of the rights claimants. Justice Jean Beetz, writing for this half of the Court, noted that section 26 of the Charter states that rights outside the Charter are not invalid, and hence the Bill of Rights still has a role to play in Canadian law. Beetz went on to find that in this case, refugees had been denied hearings, and thus their section 2(e) and fundamental justice rights were infringed. (The other half of the Court also found in favour of the claimants, but relied instead on section 7 of the Charter).