The Court emphasized that the role of institutional independence has become expected of provincial courts due to their increased role in dispute resolution in the country. As a previous judicial independence case, "Beauregard", had demonstrated, institutional independence was needed so that courts could guard the Constitution, the rule of law and fundamental justice. This required more separation of powers; whereas judicial independence has normally been understood to protect the judiciary from the executive, the Court now found the judiciary should be free of manipulation from the legislative branch. Provincial courts should benefit from this independence, as demonstrated by their handling of important cases such as "R. v. Big M Drug Mart Ltd." in 1983.