In this case, La Forest pointed to "Valente" and "R. v. Lippé" to show section 11(d) does not guarantee a type of independence that is most favourable to judges. The conclusion in "Valente" that judicial compensation committees were not needed was therefore valid; section 11(d) left room for determining what methods can be used to achieve independence. In this case, judges' salaries were lowered along with those of other government employees, and this did not seem to raise reasonable concerns about judicial independence. As a judicial compensation commission likely should not have a problem with this, as acknowledged by Lamer, La Forest found the requirement that the commission look into the matter to be "a triumph of form over substance".