doctrine was completely ignored until 1946 when Viscount Simons brought it back in the case of Ontario v. Canada Temperance Foundation, [1946] A.C. 193 (P.C.). The test as stated in Temperance Foundation was whether the matter "goes beyond local or provincial concern or interests and must from its inherent nature be the concern of the Dominion as a whole". Current approach to interpretation The above branches of the power are currently governed by the principles stated by Le Dain J. in R. v. Crown Zellerbach Canada Ltd.: Sociological value Despite its technical purpose, the phrase "peace, order and good government" has also become meaningful to Canadians. This tripartite motto is sometimes said to define Canadian values in a way comparable to “liberté, égalité, fraternité” (liberty, equality, fraternity) in France or “life, liberty and the pursuit of happiness” in the United States. It has been used by some scholars to make broad characterizations of Canada's political culture. US sociologist Seymour Martin Lipset, for example, contrasted POGG with the American tripartite motto to conclude Canadians generally believe in a higher degree of deference to the law. As Canadian historian Donald Creighton argued in his report to the Royal Commission on Dominion-Provincial Relations, the expression was used interchangeably in the 19th century by Canadian and Imperial officials with the expression peace, welfare and good government. The term welfare referred not to its more narrow modern echoes, but to the protection of the common wealth, the general public good. Good government referred to good public administration, on the one hand, but also had echoes of what we now talk of as good governance, which incorporates the notion of appropriate self-governance by civil society actors, since one element of good government was thought to be its limitation to its appropriate sphere of responsibility. Elsewhere in the Commonwealth The phrase "peace, order and good government" appears in many 19th and 20th century British Acts of Parliament, such as the New Zealand Constitution Act 1852, the Colonial Laws Validity Act 1865, the British Settlements Act 1887, the Commonwealth of Australia Constitution Act 1900, the South Africa Act 1909, Hong Kong Letters Patent 1917, and the West Indies Act 1962 and the Government of Ireland Act 1920. In Ibrelebbe v. The Queen [1964] AC 900, 923, the words "peace, order and good government" contained in the Ceylon Constitution Order-in-Council (1946) were said by the Privy Council to: "connote,