The decision of the Supreme Court was written by Peter Cory. He noted that until 1985, the Criminal Code outlawed any threat to kill or injure a person except threats spoken in front of a person. A major decision on that law was "R v Nabis" (1975), and the Parliament of Canada afterwards decided a better law was needed. The new law outlawed any kind of threat regarding bodily harm or killing. Cory found that bodily harm does not only mean killing.