stigma of the offence, there were certain offences, such as murder, where there must be proof beyond a reasonable doubt of subjective foresight. However, it was not necessary to decide that point, because it had already been settled that no conviction for any offence could occur without proof of at least objective foresight. The Court modified Vaillancourt's argument to recognize that the provision did not even require an objective fault element, which the Court recognized to be a principle of fundamental justice. Thus, since s.213(d) did not require any foresight of death it was in violation of a principle of fundamental justice and so violated s. 7 of the Charter, and could not be saved under s.1. The suggestion that high punishment/high stigma offences must have subjective fault was later adopted by a majority of the Court in R. v. Martineau, [1990] 2 SCR 633. See also List of Supreme Court of Canada cases (Dickson Court) Felony murder References External links case summary at mapleleafweb.com Section Seven Charter case law Supreme Court of Canada cases 1987 in Canadian case law Canadian criminal case law Murder in Canada