Aboriginals who did not live in those reserves. As Hogg observes, what particular rights section 25 protects was in the meantime left uncertain. Section 35 of the Constitution Act, which falls outside the Charter, does constitutionalize some aboriginal rights. As Hogg notes, this makes section 25 altogether less important than section 35, but Corbiere leaves open the possibility that rights not constitutionalized by section 35 can have some protection under section 25. Aboriginal self-government The question of how the Charter applies to Aboriginals and Aboriginal government has involved section 25. On the one hand, it has been argued that Aboriginal governments are not bound by the Charter. If section 35 includes a right to self-government, and section 25 ensures Aboriginal rights are not limited by the Charter, then section 25 would also guarantee that self-government is not limited by the Charter. On the other hand, the Royal Commission on Aboriginal Peoples once argued that while section 25 guarantees the existence of self-government itself, the powers of such Aboriginal governments will be limited to respect the Charter rights of individual Aboriginals. Some bands receive a measure of autonomy under the Indian Act, and the consequent powers of the councils would be protected by section 25. Meanwhile, section 32, which bounds the federal and provincial governments to the Charter, may not include the band councils if their authority derives not only from the Indian Act but also tradition. Amendments to section 25 In 1983, with the passing of the Constitution Amendment Proclamation, 1983, section 25 was amended to expand the protection provided for rights associated with land claims. Whereas the original wording made reference to rights acquired "by way of land claim settlement," the current version refers to rights that "now exist by way of land claims agreements or may be so acquired." While ordinarily, section 25 could have been amended with the standard 7/50 amending formula, this change was also carried out with agreement of aboriginal leaders. At the same time, the Constitution Act, 1982 was amended to add section 35.1. This new section suggests that, before section 25 is amended in the future, consultation with aboriginal leaders will again be requested by the prime minister. Case law Scholar Celeste Hutchinson remarks in an article that little has been done with section 25 by the courts. However, she points to the British Columbia Court of Appeal case R. v. Kapp as