The speaker observed that the Supreme Court of Canada has not been innovative in its approach to Administrative Law, although the fact that Canada has a written constitution and the U .K. has not should fJ!Ovide a fertile area for distinctive Canadian contributions in Administrative Law. Although the Roncarelli decision required the Court to look at policy in protecting individual rights against the state, the Court has generally failed to formulate policy and clear precedent and has not yet evolved a coherent body of Administrative Law.