For these reasons, it was strongly suggested that the government establish judicial salary commissions, thus overruling "obiter dicta" in the previous landmark judicial independence case, "Valente v. The Queen", which had found such commissions were desirable but not necessary. In this case, it was noted commissions could guard against manipulation by both the executive "and" legislatures. If remuneration of provincial judges is to be raised, lowered or kept the same, this may be done along with the remuneration of other government employees or with the judges' alone. The continued independence of judges, however, will be kept apparent in any of these circumstances if it involves review by an "independent, effective, and objective" body, i.e. the salary commissions. While salary recommendations of these commissions should not be binding, they should be taken seriously. Any government rejection of a recommendation will have to be justified and may be challenged in a court. However, the justification need not be scrutinized to the extent that a government decision will be scrutinized under Section One of the Canadian Charter of Rights and Freedoms. Instead, governments must only show their rejections are rational, and rationality can be measured in the way it was measured by the Supreme Court in "Reference re Anti-Inflation Act" (1976).