put the women at higher risk of physical harm and caused harm to their psychological integrity. Following a standard section 7 analysis, Dickson examined whether the violation accorded with the principles of fundamental justice. He found that it did not because the excessive requirements prevented smaller hospitals from providing such services thus preventing many women from even applying for certification. Moreover, he found that the administrative system failed to provide adequate evaluation criteria which allowed the committees to grant or deny therapeutic abortions arbitrarily. Dickson found that the violation could not be justified under section 1, focusing on the means chosen by the government to achieve its objectives. In the end, the law failed on every step of the proportionality test. First, he found the administrative process was often unfair and arbitrary. Second, the resultant impairment of the women's rights was beyond what was necessary to evaluate their case. Third, the effect of the impairment far outweighed the importance of the law's objective. Beetz Justice Jean Beetz, joined by Justice Willard Estey, wrote a second opinion finding the abortion law invalid. In it, Beetz noted that by adopting section 251(4), the government acknowledged that the interest of the state to protect the woman is greater than its interest to protect the fetus when "the continuation of the pregnancy of such female person would or would be likely to endanger her life or health". Beetz's reasoning closely resembled that of the Chief Justice. He found a violation of section 7 as the procedural requirements of section 251 were "manifestly unfair". Beetz's reasoning in the section 1 analysis was also similar to that of Dickson. He found that the objective had no rational connection to the means, meaning the law could not be justified. He also speculated that if the government were to enact a new abortion law, this law would require a higher degree of danger to the woman in the later months rather than the early months for an abortion to be allowed. In this case, it could be sufficiently justifiable under section 1. In examining whether the law was ultra vires, Beetz examined sections 91 and 96 of the Constitution Act, 1867. He decided that the law was within the power of the federal government on account that the committee was not given any power over any provincial jurisdiction under section 91 nor did it function in any sort