unanimous court. He held that those sections of the Immigration Act addressed a valid subject matter of the federal government, and that M was allowed to practice law in front of the Board under the provisions of the Immigration Act. Given the clear overlap of laws, Gonthier considered whether to apply the paramountcy doctrine or the inter-jurisdictional immunity doctrine to resolve the conflict. He found that the paramountcy doctrine was more appropriate as there was a clear double aspect in the law. The first part of the paramountcy test asks whether there is an "operational conflict between federal and provincial laws", where "compliance with one is defiance of the other". Gonthier found that the purpose of the federal law was to authorize non-lawyers to appear as counsel in immigration tribunals for a fee, but the provincial law made exercise of the authority impossible. Consequently, the paramountcy doctrine could be invoked and the provincial law was held to be inoperative to the extent of the conflict. See also List of Supreme Court of Canada cases (McLachlin Court) References External links Canadian immigration and refugee case law Canadian federalism case law Supreme Court of Canada cases 2001 in Canadian case law