In written law, the term "fundamental justice" can be traced back at least to 1960, when the "Canadian Bill of Rights" was brought into force by the Diefenbaker government. Specifically, section 2(e) of the "Canadian Bill of Rights" stated that everyone has "the right to a fair hearing in accordance with the principles of fundamental justice for the determination of his rights and obligations." According to the legal scholar Walter Tarnopolsky, the wording of the clause sparked some controversy among those drafting the Bill. Some wanted the words "natural justice" in the place of "fundamental justice," as "natural justice" was indeed a more common phrase with judges and authors. "Fundamental justice" was a more obscure alternative with these figures (other such alternatives include "universal justice"). Still, "fundamental justice" was chosen, and in the case "Duke v. The Queen" (1972), it was ruled that fundamental justice was, for the purposes of this case, merely equivalent to natural justice. The author, Chief Justice Fauteux, did say that he was not trying "to formulate any final definition."