the officer or managerial level employee to be a vital organ of the company and virtually its directing mind in the sphere of duty assigned him so that his actions and intent are the action and intent of the company itself, the company can be held criminally liable. The directing mind must act within the scope of his authority i.e., his actions must be performed within the sector of the corporate operation assigned to him. The sector may be functional, or geographic, or may embrace the entire undertaking of the corporation. However, the doctrine will not extend to cases where the directing mind intentionally defrauds the corporation and when his wrongful actions form the substantial part of the regular activities of his office. Thus, the identification doctrine only operates where the Crown demonstrates that the action taken by the directing mind: was within the field of operation assigned to him, was not totally in fraud of the corporation, and was by design or result partly for the benefit of the company. In this appeal, the Crown's case was successful. As Estey J noted: Impact and subsequent events Canadian Dredge marked a departure of Canadian jurisprudence in the matter of corporate liability from that determined in other Commonwealth jurisprudence, most notably in Tesco Supermarkets Ltd v Nattrass. As Estey J explained: However, it did confirm the rejection of US jurisprudence on the subject, which has favoured the use of the doctrine of vicarious liability: The identification doctrine was further elaborated upon in The Rhone v. The Peter A.B. Widener, where Iacobucci J stated: In 2003, the Criminal Code was amended to revise the rules relating to criminal liability, including: extending liability to organizations that are not corporations, distinguishing between offences that involve negligence and those involving other types of fault, and prescribing a legal duty for anyone directing the work of another person to take reasonable steps to prevent bodily harm to that person, or any other person, arising from that work or task. References Supreme Court of Canada cases 1985 in Canadian case law Canadian criminal case law Canadian corporate case law Dredging