Toronto Electric Commissioners v. Snider, [1925] AC 396 is a famous Canadian constitutional decision of the Judicial Committee of the Privy Council where the Council struck down the federal Industrial Disputes Investigation Act, precursor to the Canada Labour Code. The Court identified matters in relation to labour to be within the exclusive competence of the province in the property and civil rights power under section 92(13) of the Constitution Act, 1867. This decision is considered one of the high water-marks of the Council's interpretation of the Constitution in favour of the provinces.
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In 1923, the employees for the Toronto Electric Commission, through the Canadian Electrical Trades Union, went on strike over working conditions and wages. The union applied under the Industrial Disputes Investigation Act to establish a dispute resolution board. The Commission did not want to recognize the authority of the board and so applied to have the Act invalidated as ultra vires of the federal government.
Lord Haldane held that the Act could not be upheld under the "emergency" doctrine of the federal peace, order and good government power. The power could only be used in times of extraordinary peril and emergency, but it cannot be used to unjustifiably override the provinces' property and civil rights power.