The Court turned back to examine section 11(d) and from precedent, namely "Valente v. The Queen", identified three fundamental requirements of judicial independence: 1) security of tenure, 2) financial security, and 3) some administrative independence. As well, judicial independence can be divided into two types of independence: 1) individual independence belonging to a judge and 2) institutional independence of a court as a whole. A judge must also be reasonably seen as being independent. It is possible, Lamer found, to interpret each of the three requirements in light of the two types of independence; this case, in particular, would explore how financial security belongs to both a judge and the court as a whole. This discussion would go beyond "Valente", since that decision only treated financial security as a matter of individual independence.