R v Canadian Dredge & Dock Co is a landmark Supreme Court of Canada decision on corporate liability where the Court adopted the English identification doctrine for liability, which states that culpability for acts and mental states of a corporation can be represented by employees and officers on the basis that they are the "directing mind" of the corporate entity. Background In 19671973, the Government of Canada issued a series of tenders for dredging operations performed in the Saint Lawrence River and several of the Great Lakes, for which contracts were granted. It was later discovered that a process of bid rigging had occurred, and a complex trial involving twenty defendants took place. Among the defendants were four corporations (Canadian Dredge & Dock Company, Marine Industries Limited, The J.P. Porter Company Limited, and Richelieu Dredging Corporation Inc.) which were charged and convicted with the offences of fraud and conspiracy under the Criminal Code in effect at the time. The Ontario Court of Appeal dismissed all appeals relating to the convictions, and the defendants appealed to the Supreme Court of Canada on the following issues: Is the criminal liability of a corporation, when it is based on the misconduct of a directing mind of the corporation, affected because the person who is the directing mind is at the same time acting, in whole or in part, in fraud of the corporation, or wholly or partly for his own benefit or contrary to instructions that he not engage in any illegal activities in the course of his duties? Was there any evidence that a directing mind of the applicant corporation was acting wholly or in part in fraud of the corporation during the period covered by the indictments herein or acting wholly or in part for his own benefit during that period or contrary to instructions that he not engage in illegal activities in the course of his duties and, if so, is the criminal liability of the corporation affected by any one or more of such circumstances? Opinion of the Court All appeals were dismissed. Estey J, for a unanimous Court, held the four companies liable of bid rigging under the identification doctrine, which assigns primary liability as opposed to vicarious liability to a corporation where the actor‑employee who physically committed the offence is the ego of it. As he observed: Therefore, even in mens rea offences, if the court finds