to one of them will deal with the issue. For example, if the provision in question has no relation to the regulatory scheme, the question of its validity may be quickly answered on that ground alone. Use outside of Canada The pith and substance doctrine as applied in the jurisprudence of the Judicial Committee of the Privy Council, effectively the British Imperial Court of Appeal, has been carried to other Commonwealth federations. It is used in the Indian Constitution. It was also used in Northern Ireland under the Government of Ireland Act 1920. The substance of the doctrine has been cast in statutory form in the Scotland Act 1998 for the purpose of devolution to Scotland. It was also used in Australia until 1964, when the High Court case of Fairfax v Commissioner of Taxation overruled its use by an alternate method. In India It is used in the Indian Constitution. The doctrine has been applied in India also to provide a degree of flexibility in the otherwise rigid scheme of distribution of powers. The reason for adoption of this doctrine is that if every legislation were to be declared invalid on the grounds that it encroached powers, the powers of the legislature would be drastically circumscribed. Cases relating to Pith and Substance.- Central Bank Of India vs State Of Kerala & Ors on 27 February, 2009 Ms Bharti Telemedia Limited vs Chief Secretory on 30 January, 2014 State Of Maharashtra vs Bharat Shanti Lal Shah & Ors on 1 September, 2008 The Gujarat University vs Krishna Ranganath Mudholkar And ... on 21 February, 1962 Zameer Ahmed Latifur Rehman ... vs State Of Maharashtra & Ors on 23 April, 2010 Citation in the matter of M/s. Sky Gourmet Catering Private Limited V/s Tax Authorities (Commercial Tax and Service Tax) in the matter of Writ Appeal No. 671 to 726 of 2011 (T-Res) decided on 18th day of April, 2011 by Hon'ble High Court of Karnataka at Bangalore may also be seen. See also References Significant cases Constitution of Canada Federalism in Canada Constitution of India Legal doctrines and principles