to believe the only motive for using the power was political interference. By 1911 the practice of disallowing provincial bills had become very infrequent. A notable use of disallowance in the 20th century was its use by federal Justice Minister Ernest Lapointe in the 1930s and 1940s to strike down various laws of Alberta's Social Credit government, which tried to legislate in the clearly defined federal powers of banking and currency. The last disallowance of a provincial law occurred in April 1943, in relation to Alberta legislation restricting land sales regarding Hutterites and "enemy aliens." The last reservation of a provincial law occurred in 1961, when Saskatchewan Lieutenant Governor Frank Lindsay Bastedo, without the instruction or knowledge of the federal government, reserved a CCF government's bill regarding mining contracts. The Diefenbaker Cabinet quickly passed an order-in-council to grant royal assent. Both powers, while still operative, are generally considered dormant, prompting some debates about whether they have effectively become obsolete through disuse. Comparative public law scholar Richard Albert has argued that both powers have fallen into "constitutional desuetude," which occurs "when an entrenched constitutional provision loses its binding force upon political actors as a result of its conscious sustained nonuse and public repudiation by preceding and present political actors." Removal of both powers from the constitution was contemplated in the failed Victoria Charter. The first ministers decided not to include abolition in the Constitution Act, 1982, and attempts to revise the powers included in the Charlottetown Accord failed at referendum. Consideration of disallowance and reservation after 1961 The government of Pierre Trudeau faced public pressure to disallow Quebec's Charter of the French Language in 1977, which forbade the use of English language signs and openly contravened some procedural linguistic rights protected by the British North America Act. Trudeau, a constitutional scholar, demurred, believing that disallowance would ultimately cause more political harm, and that it was better to have the conflicting matters adjudicated. Trudeau believed that disallowance was warranted only for laws that clearly violated federal power or that created disorder beyond the boundaries of the province enacting the law. In 2018, the government of Justin Trudeau was formally asked by Toronto City Council to disallow Ontario's pending Efficient Local Government Act (Bill 31), a bill intended to force the reduction of the number of wards represented in the Toronto City Council after the government's previous attempt to do so was ruled