Morgentaler case divides Supreme Court in interpretation of Criminal Code By Donald Phillipson The Morgentaler case has been settled, and the Montreal physician now is serving his 18-month sentence for performing an illegal abortion. The Supreme Court of Canada, by six votes to three, upheld Dr. Henry Morgentaler's conviction in the Que¬ bec Court of Appeal, the chief justice among those dissenting. This brings to an end a 5-year campaign between Dr. Morgentaler and the Quebec attorney general's department, the Crown's agent for applying the criminal law. The three opinions issued by Su¬ preme Court justices explicitly abstain from participation in debate about whether the abortion law (section 251) belongs in the Criminal Code or wheth¬ er it is being fairly applied in all cases. But the decision has already initiated debate on a legal point of far wider application: the prerogative of an appeals court to convict a man previously
acquitted by a jury. The Morgentaler case is generally accepted to be the first time that this prerogative has been exercised. Dr. Morgentaler was charged with the illegal abortion Aug. 15, 1973 of Verona Parkinson at his Montreal clin¬ ic. It was far from the first such charge but was the first to come to trial, under "preferred indictment" of the attorney general. Earlier charges had been de¬ layed by legal steps, characterized by one judge as an abuse of procedure and "an attempt to make a mockery of the administration of justice." This time, Dr. Morgentaler came to
trial in the Court of Queen's Bench within 10 weeks. Defence Counsel Claude-Armand Sheppard argued that the abortion was both "reasonable" and "for the benefit" of the patient and, therefore, immune from legal sanction under section 45 of the Criminal Code. The trial judge allowed this line of defence as a point of law, and the jury acquitted Dr. Morgentaler.
Appeal; or it could decide the disputed questions of law and then order a new trial in the lower courts. Juridical opinions were written by three of the Supreme Court justices. Finding for the Crown, Mr. Justice Pigeon set out the law allowing appeal court judges to convict a man acquitted by a jury and Mr. Justice Dickson, the abortion law, section 251. Dissenting, Chief Justice Bora Laskin outlined why the constitutionality of section 251 was upheld and discussed the availability of section 45 as a defence and the powers of judges in ascertaining mat¬ ters of law and juries in deciding upon the evidence. Mr. Justice Dickson's opinion em¬ ment was generally thought to set a record for bulk in Canadian jurisprud- phasized that the Supreme Court "has not been called upon to decide, or even ence. to enter, the loud and continuous pub¬ lic debate" between extremes of at¬ Arguments varied widely titude towards abortion but to settle matters of law: whether either necessity In the Supreme Court, the appellant or section 45 of the Criminal Code is appears first. For Dr. Morgentaler, a a defence against a charge of illegal wide variety of arguments were ad¬ abortion. He concluded that subsection (4) of vanced, including: that the abortion law was unconstitutional; that section section 251 "is intended to afford, and 45 and the commonlaw principle of does afford, a complete answer and necessity were legitimate defences; that defence to those who respect its terms." section 251 was not intended to pro- These establish nine requirements, from hibit medically sound abortions by li- review by a therapeutic abortion com¬ censed practitioners; and that no court mittee to the delivery of its certificate, of appeal should convict a man ac¬ and "the plain fact is that appellant made no attempt to bring himself with¬ quitted by a jury. The constitutionality of the abortion in the bounds of legality in deciding law was upheld by the Supreme Court to perform this abortion," Mr. Justice justices part-way through the trial, and Dickson wrote. In the matter of the jury's prerogasome of the information about unequal access by patients to abortion tives vis-a-vis those of the judges, Judge
The Crown appealed, and the Que¬ bec Court of Appeals decided unanimously that section 45 was not an avail¬ able line of defence in this case. It therefore ordered a verdict of guilty and directed the trial judge to pass sentence, which he did. The defence appealed to the Su¬ preme Court of Canada, which heard the case Oct. 2 to 7, 1974, and de¬ livered its judgement Mar. 26, 1975 upholding the decision of the Quebec Court of Appeal. Several organizations, including the Canadian Civil Liberties Association and the Alliance for Life, were allowed to intervene in the case, and the whole body of written argu-
committees was ruled extraneous. The trial thus focused on the last three points enumerated above. The Supreme Court had three alter¬ native verdicts: it could find for the appellant and acquit Dr. Morgentaler; it could dismiss the appeal and uphold the conviction of the Quebec Court of
Dickson concluded that "it is proper and at times indeed essential for an appellate court to examine the record with a view to ascertaining whether there is any evidence to support a de¬ fence. * Evidence from which a jury .
*
..
Emphasis in original.
CMA JOURNAL/APRIL 19, 1975/VOL. 112 1003
could conclude it was impossible for appellant to comply with the law is wholly wanting." Therefore the Qu6bec Court of Appeal was quite right to reverse the jury's acquittal. Mr. Justice Pigeon considered at length this prerogative of the high court. The written law clearly provides that a court of appeal may enter a verdict of guilty. This is "a major departure from the traditional principles of English criminal law," wrote Mr. Justice Pigeon, but the law (and thus the presumed intent of Parliament in making it) is unmistakable. In this case, Dr. Morgentaler "admitted the fact and denied his guilt only on the basis of some defences which the Court of Appeal rightly held unavailable, one of them (section 45) because it was unfounded in law, the
other (necessity) because there was no evidence to support it." Thus Mr. Justice Pigeon and a majority of the judges upheld the conviction. Dissenting, Chief Justice Bora Laskin concluded "not only.., that section 45 remains available as a defence but also that there was evidence upon which the trial judge could leave that defence to the jury." It is for the jury to decide whether, in some particular case, there is any evidence to sustain a section 45 defence, the chief justice wrote. He further noted that the five appeals court justices differed among themselves, as to the permissibility of evidence supporting defences of necessity or under section 45 and commented that, as Defence Counsel ClaudeArmand Sheppard argued, permitting a section 45 defence does not imply
abortion on demand (as some appeals court judges had postulated). There was "some.. evidence of necessity in this case, the chief justice wrote, so it was up to the jury to decide whether there was enough or not: "the sufficiency of evidence on any issue is a matter for the jury." Thus both lines of defence were legally available to Dr. Morgentaler in this case, the chief justice concluded; the jury thought that the evidence was enough, so its acquittal should have been upheld. Had one line of defence been admissible and the other not, a new trial should have been ordered. The conviction was upheld by Justices Pigeon, Dickson, Martland, Ritchie, Beetz, and de Grandpr., with the chief justice and Justices Judson and Spence dissenting.E
May CAThOLIC HOSPITAL ASSOCIATION OF CANADA, May 1-3, Chateau Laurler, Ottawa. Info: Catholic Hospital Association of Canada, 312 Daly Ave., Ottawa KiN 6G7.
Conference: ISSUES IN INTERPROFESSIONAL EDUCATION FOR HEALTH CARE PRACTICE, May 15-16, HamIlton, Ont. Info: Anne Myers, McMaster UniversIty, 1200 Main St. W, Hamilton, Ont. LBS 4J9
CANADIAN PUBLIC HEALTH ASSOCIATION, May 26-30, MacDonald Hotel, Edmonton. Info: CPHA, 55 Parkdaie Ave., Ottawa KIY IES.
COLLEGE OF FAMILY PHYSICIANS OF CANADA, SASKATCHEWAN CHAPTER, May 1-3, Regina. Info: Ms. Margeret Sarich, 408 EllIs Hall, Saskatoon, Sask. S7N 0W8. Day with the CATARACT SURGEONS, May 2, UnIversity of Western Ontario, London. Info: Dept. of Ophthalmology, University of Western Ontario, 3 North Victoria Hospital, London N6A 4G5. Seminar HOME CARE INFORMATION SYSTEMS, May 5-7, Ottawa. Info: Carolyn Beizile, School of health administration, University of Ottawa, Ottawa KiN 6N5. ONTARIO MEDICAL ASSOCIATION, May 5-9, London, Ont. Info: Dr. F. T. H. Porter, 240 St. George St., Toronto M5R 2P4. Seminar, PROGRAMS AND SERVICES FOR THE AGED: TOWARDS AN INTEGRATED DELIVERY SYSTEI.I, May 5.7, Ottawa. Info: Carolyn Beizile. School of health administration, University of Ottawa. Ottawa KiN 6N5. MUSCLE SPINDLES' FUNCTIONS, Hughilngs Jackson Lecture, May 7, AmphItheatre of the Montreal Neurological Institute. Info: Dr. William Feindel, Montreal Neurological Institute, McGill University, Montreal. 19th annual symposium on CANCER, May 8-9, Auditorium, Museum of Natural History, Regina. Info: Saskatchewan Medical Association, Dr. E.H. Baergan, 211 Fourth Ave. 5, Saskatoon S7K iNi. BRITISH COLUMBIA MEDICAL ASSOCIATION. May 8-10, Kamloops, BC. Info: Dr. Norman Rigby, BCMA, 1807 W 10th Ave., Vancouver V8J 2A9. MANITOBA MEDICAL ASSOCIATION, May 10, Brandon, Man. Info: R.P.H. Sprague, MMA, 201 Kennedy St., Winnipeg R3C 1S8. ONTARIO SOCIETY OF CLINICAL HYPNOSIS, May 9.11 Hyatt Regency Hotel, Toronto. Info: Dr. Stan Kushnir, Ontario Society of Clinical Hypnosis, 243 St. Clair Ave. W, Toronto. 38th adnual meeting, CANADIAN ASSOCIATION OF RADIOLOGISTS, May 11-15, Sheraton Four Seasons Toronto. Info: Dr. Ross Hill, Ste. 806, 1440 St. Catherine St. W., Montreal, 0u6 H3G I RB CANADIAN OTOLARYNGOLOGICAL SOCIETY, May 12-14, Montreal. Info: Dr. David Briant, Canadian Otolaryngological SocIety, 1673 Caning Ave., Ottawa.
International symposium, HEALTH CHEMICALS IN FOODS, sponsored protection branch, DNH&W, May Info: Ms. Jean Renaud, Room 1-8, Ottawa KiA 012
EFFECTS OF by the health 12-14, Ottawa. HPB, DNH&W,
Day in therapeutics, ANESTHETIC EMERGENCIES, May 14, North Bay, Ont. Info: Ontario Medical FoundatIon, 242 St. George St., Toronto M5R 2P4. Day in therapeutics, COMPLICATIONS IN THE RE. COVERY ROOM, May 15, Kirkland Lake, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. Day in therapeutics, HIGH ANESTHETIC RISKS, May 16, Tlmmins, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. RESPIRATORY PATHOPHYSIOLOGY, May 15-17, Montr6al. Info: Registrar, Postgraduate courses, American College of Physici.ns, 4200 Pine St., Philadelphia, PA 19104. Symposium, HIGH RISK PREGNANCY, May 15-16, Calgary. Info: Dr. E.G. Trueman, High Risk Pregnancy Symposium, Foothills Hospital, Calgary T2N 2T9. Symposium, PHYSICALLY HANDICAPPED CHILD, HIS HOME, HIS SCHOOL AND HIS COMMUNITY, May 16-17, WinnIpeg. Info: Dr. Mervyn Letta, Health Sciences Children's Centre, 685 Bannatyne Ave., Winnipeg R3E OWl.
OUEBEC MEDICAL ASSOCIATION, May 16-17, Sherbrooke. Info: G. Blouln, OMA, 1350 Sherbrooke St. W., Suite 1410, Montreal 109, P.O. Conjoint Meeting, CANADIAN TUBERCULOSIS AND RESPIRATORY DISEASE ASSOCIATION, AMERICAN LUNG ASSOCIATION, CANADIAN THORACIC SOCIETY, AMERICAN THORACIC SOCIETY, May 18-21, Oueen Elizabeth Hotel, Montreal. Info: H. E. Drouln, CTRDA, 345 OConnor St., Ottawa K2P 1V9.
Seminar, ACCREDITATION OF PSYCHIATRIC FACILITIES, May 26-28, Ottawa. Info: Carolyn Belzile, School of health administration, University of Ottawa, Ottawa KiN 6N5. Day In therapeutics, MANAGEMENT OF THE OLDER PATIENT, Sarnia, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. CANADIAN SOCIETY OF PLASTIC SURGEONS, May 28-31, Toronto. Info: Dr. H.J. Shimlzu, #4308409 112 St. Edmonton, T6G 1K6
June NEWFOUNDLAND MEDICAL ASSOCIATION, June 4-7, Gander. Info: G. Lynch, NMA, OMara-Martin Bldg., Rawlins Cross, St. Johns, Nfld. International symposium, CHILD WITH CONGENITAL HEART DISEASE AFTER SURGERY, June 5-7, Inn on the Park Hotel, Toronto. Info: Ontario Heart Foundation, Professional education, 310 Davenport Rd., Toronto M5R 3K2. Combined centennial meetings, CANADIAN PAEDIATRIC SOCIETY, SOCIETY FOR ADOLESCENT MEDICINE, AMBULATORY PAEDIATRIC ASSOCIATION, HOSPITAL FOR SICK CHILDREN ALUMNI, June 7-12, Toronto. Info: Dr. J.W. Balfe, Nephrology dept., Hospital for Sick Children, Toronto, Ont. Seminar, CONFLICTS IN THE PHYSICAL REHABILITATION TEAM, June 9-10, Ottawa. Info: Carolyn Beizile, School of Health AdminIstration, University of Ottawa, Ottawa KiN 6N5. Annual meeting, CANADIAN CANCER SOCIETY, June 13, GeorgIa Hotel, Vancouver. Info: Alan MartIn, Canadian Cancer Society, 25 AdelaIde St. E, Toronto M5C 1Y2.
INTERNATIONAL CHILDBIRTH EDUCATION ASSO. CIATION, May 20-23, HamIlton, Ont. Info: Lynn Gilbank, ICEA Canadian Conference, 149 Woodview Cres., Ancaster, Ont. L9G iGi.
Seminar, HEALTH ADMINISTRATION RESEARCH FORUM, June 16-17, Ottawa. Info: Carolyn Beizile, School of health administration, University of Ottawa, Ottawa KiN 6N5.
CANADIAN ORTHOPAEDIC ASSOCIATION, May 25-29, Ottawa. Info: Dr. R. 1. Cruess, Canadian Orthopsedlc Assn., 5470 Oueen Mary Rd., Suite 1, Montreal 248, P.O.
10th CanadIan Congress of .4EUROLOGICAL SCIENCES, June 18-21, London. Info: Dr. A. J. Hudson, University Hospital, 339 Wlndermere Road, London N6G 2K3
1004 CMA JOURNAL/APRIL 19, 1975/VOL 112
acquitted by a jury. The Morgentaler case is generally accepted to be the first time that this prerogative has been exercised. Dr. Morgentaler was charged with the illegal abortion Aug. 15, 1973 of Verona Parkinson at his Montreal clin¬ ic. It was far from the first such charge but was the first to come to trial, under "preferred indictment" of the attorney general. Earlier charges had been de¬ layed by legal steps, characterized by one judge as an abuse of procedure and "an attempt to make a mockery of the administration of justice." This time, Dr. Morgentaler came to
trial in the Court of Queen's Bench within 10 weeks. Defence Counsel Claude-Armand Sheppard argued that the abortion was both "reasonable" and "for the benefit" of the patient and, therefore, immune from legal sanction under section 45 of the Criminal Code. The trial judge allowed this line of defence as a point of law, and the jury acquitted Dr. Morgentaler.
Appeal; or it could decide the disputed questions of law and then order a new trial in the lower courts. Juridical opinions were written by three of the Supreme Court justices. Finding for the Crown, Mr. Justice Pigeon set out the law allowing appeal court judges to convict a man acquitted by a jury and Mr. Justice Dickson, the abortion law, section 251. Dissenting, Chief Justice Bora Laskin outlined why the constitutionality of section 251 was upheld and discussed the availability of section 45 as a defence and the powers of judges in ascertaining mat¬ ters of law and juries in deciding upon the evidence. Mr. Justice Dickson's opinion em¬ ment was generally thought to set a record for bulk in Canadian jurisprud- phasized that the Supreme Court "has not been called upon to decide, or even ence. to enter, the loud and continuous pub¬ lic debate" between extremes of at¬ Arguments varied widely titude towards abortion but to settle matters of law: whether either necessity In the Supreme Court, the appellant or section 45 of the Criminal Code is appears first. For Dr. Morgentaler, a a defence against a charge of illegal wide variety of arguments were ad¬ abortion. He concluded that subsection (4) of vanced, including: that the abortion law was unconstitutional; that section section 251 "is intended to afford, and 45 and the commonlaw principle of does afford, a complete answer and necessity were legitimate defences; that defence to those who respect its terms." section 251 was not intended to pro- These establish nine requirements, from hibit medically sound abortions by li- review by a therapeutic abortion com¬ censed practitioners; and that no court mittee to the delivery of its certificate, of appeal should convict a man ac¬ and "the plain fact is that appellant made no attempt to bring himself with¬ quitted by a jury. The constitutionality of the abortion in the bounds of legality in deciding law was upheld by the Supreme Court to perform this abortion," Mr. Justice justices part-way through the trial, and Dickson wrote. In the matter of the jury's prerogasome of the information about unequal access by patients to abortion tives vis-a-vis those of the judges, Judge
The Crown appealed, and the Que¬ bec Court of Appeals decided unanimously that section 45 was not an avail¬ able line of defence in this case. It therefore ordered a verdict of guilty and directed the trial judge to pass sentence, which he did. The defence appealed to the Su¬ preme Court of Canada, which heard the case Oct. 2 to 7, 1974, and de¬ livered its judgement Mar. 26, 1975 upholding the decision of the Quebec Court of Appeal. Several organizations, including the Canadian Civil Liberties Association and the Alliance for Life, were allowed to intervene in the case, and the whole body of written argu-
committees was ruled extraneous. The trial thus focused on the last three points enumerated above. The Supreme Court had three alter¬ native verdicts: it could find for the appellant and acquit Dr. Morgentaler; it could dismiss the appeal and uphold the conviction of the Quebec Court of
Dickson concluded that "it is proper and at times indeed essential for an appellate court to examine the record with a view to ascertaining whether there is any evidence to support a de¬ fence. * Evidence from which a jury .
*
..
Emphasis in original.
CMA JOURNAL/APRIL 19, 1975/VOL. 112 1003
could conclude it was impossible for appellant to comply with the law is wholly wanting." Therefore the Qu6bec Court of Appeal was quite right to reverse the jury's acquittal. Mr. Justice Pigeon considered at length this prerogative of the high court. The written law clearly provides that a court of appeal may enter a verdict of guilty. This is "a major departure from the traditional principles of English criminal law," wrote Mr. Justice Pigeon, but the law (and thus the presumed intent of Parliament in making it) is unmistakable. In this case, Dr. Morgentaler "admitted the fact and denied his guilt only on the basis of some defences which the Court of Appeal rightly held unavailable, one of them (section 45) because it was unfounded in law, the
other (necessity) because there was no evidence to support it." Thus Mr. Justice Pigeon and a majority of the judges upheld the conviction. Dissenting, Chief Justice Bora Laskin concluded "not only.., that section 45 remains available as a defence but also that there was evidence upon which the trial judge could leave that defence to the jury." It is for the jury to decide whether, in some particular case, there is any evidence to sustain a section 45 defence, the chief justice wrote. He further noted that the five appeals court justices differed among themselves, as to the permissibility of evidence supporting defences of necessity or under section 45 and commented that, as Defence Counsel ClaudeArmand Sheppard argued, permitting a section 45 defence does not imply
abortion on demand (as some appeals court judges had postulated). There was "some.. evidence of necessity in this case, the chief justice wrote, so it was up to the jury to decide whether there was enough or not: "the sufficiency of evidence on any issue is a matter for the jury." Thus both lines of defence were legally available to Dr. Morgentaler in this case, the chief justice concluded; the jury thought that the evidence was enough, so its acquittal should have been upheld. Had one line of defence been admissible and the other not, a new trial should have been ordered. The conviction was upheld by Justices Pigeon, Dickson, Martland, Ritchie, Beetz, and de Grandpr., with the chief justice and Justices Judson and Spence dissenting.E
May CAThOLIC HOSPITAL ASSOCIATION OF CANADA, May 1-3, Chateau Laurler, Ottawa. Info: Catholic Hospital Association of Canada, 312 Daly Ave., Ottawa KiN 6G7.
Conference: ISSUES IN INTERPROFESSIONAL EDUCATION FOR HEALTH CARE PRACTICE, May 15-16, HamIlton, Ont. Info: Anne Myers, McMaster UniversIty, 1200 Main St. W, Hamilton, Ont. LBS 4J9
CANADIAN PUBLIC HEALTH ASSOCIATION, May 26-30, MacDonald Hotel, Edmonton. Info: CPHA, 55 Parkdaie Ave., Ottawa KIY IES.
COLLEGE OF FAMILY PHYSICIANS OF CANADA, SASKATCHEWAN CHAPTER, May 1-3, Regina. Info: Ms. Margeret Sarich, 408 EllIs Hall, Saskatoon, Sask. S7N 0W8. Day with the CATARACT SURGEONS, May 2, UnIversity of Western Ontario, London. Info: Dept. of Ophthalmology, University of Western Ontario, 3 North Victoria Hospital, London N6A 4G5. Seminar HOME CARE INFORMATION SYSTEMS, May 5-7, Ottawa. Info: Carolyn Beizile, School of health administration, University of Ottawa, Ottawa KiN 6N5. ONTARIO MEDICAL ASSOCIATION, May 5-9, London, Ont. Info: Dr. F. T. H. Porter, 240 St. George St., Toronto M5R 2P4. Seminar, PROGRAMS AND SERVICES FOR THE AGED: TOWARDS AN INTEGRATED DELIVERY SYSTEI.I, May 5.7, Ottawa. Info: Carolyn Beizile. School of health administration, University of Ottawa. Ottawa KiN 6N5. MUSCLE SPINDLES' FUNCTIONS, Hughilngs Jackson Lecture, May 7, AmphItheatre of the Montreal Neurological Institute. Info: Dr. William Feindel, Montreal Neurological Institute, McGill University, Montreal. 19th annual symposium on CANCER, May 8-9, Auditorium, Museum of Natural History, Regina. Info: Saskatchewan Medical Association, Dr. E.H. Baergan, 211 Fourth Ave. 5, Saskatoon S7K iNi. BRITISH COLUMBIA MEDICAL ASSOCIATION. May 8-10, Kamloops, BC. Info: Dr. Norman Rigby, BCMA, 1807 W 10th Ave., Vancouver V8J 2A9. MANITOBA MEDICAL ASSOCIATION, May 10, Brandon, Man. Info: R.P.H. Sprague, MMA, 201 Kennedy St., Winnipeg R3C 1S8. ONTARIO SOCIETY OF CLINICAL HYPNOSIS, May 9.11 Hyatt Regency Hotel, Toronto. Info: Dr. Stan Kushnir, Ontario Society of Clinical Hypnosis, 243 St. Clair Ave. W, Toronto. 38th adnual meeting, CANADIAN ASSOCIATION OF RADIOLOGISTS, May 11-15, Sheraton Four Seasons Toronto. Info: Dr. Ross Hill, Ste. 806, 1440 St. Catherine St. W., Montreal, 0u6 H3G I RB CANADIAN OTOLARYNGOLOGICAL SOCIETY, May 12-14, Montreal. Info: Dr. David Briant, Canadian Otolaryngological SocIety, 1673 Caning Ave., Ottawa.
International symposium, HEALTH CHEMICALS IN FOODS, sponsored protection branch, DNH&W, May Info: Ms. Jean Renaud, Room 1-8, Ottawa KiA 012
EFFECTS OF by the health 12-14, Ottawa. HPB, DNH&W,
Day in therapeutics, ANESTHETIC EMERGENCIES, May 14, North Bay, Ont. Info: Ontario Medical FoundatIon, 242 St. George St., Toronto M5R 2P4. Day in therapeutics, COMPLICATIONS IN THE RE. COVERY ROOM, May 15, Kirkland Lake, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. Day in therapeutics, HIGH ANESTHETIC RISKS, May 16, Tlmmins, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. RESPIRATORY PATHOPHYSIOLOGY, May 15-17, Montr6al. Info: Registrar, Postgraduate courses, American College of Physici.ns, 4200 Pine St., Philadelphia, PA 19104. Symposium, HIGH RISK PREGNANCY, May 15-16, Calgary. Info: Dr. E.G. Trueman, High Risk Pregnancy Symposium, Foothills Hospital, Calgary T2N 2T9. Symposium, PHYSICALLY HANDICAPPED CHILD, HIS HOME, HIS SCHOOL AND HIS COMMUNITY, May 16-17, WinnIpeg. Info: Dr. Mervyn Letta, Health Sciences Children's Centre, 685 Bannatyne Ave., Winnipeg R3E OWl.
OUEBEC MEDICAL ASSOCIATION, May 16-17, Sherbrooke. Info: G. Blouln, OMA, 1350 Sherbrooke St. W., Suite 1410, Montreal 109, P.O. Conjoint Meeting, CANADIAN TUBERCULOSIS AND RESPIRATORY DISEASE ASSOCIATION, AMERICAN LUNG ASSOCIATION, CANADIAN THORACIC SOCIETY, AMERICAN THORACIC SOCIETY, May 18-21, Oueen Elizabeth Hotel, Montreal. Info: H. E. Drouln, CTRDA, 345 OConnor St., Ottawa K2P 1V9.
Seminar, ACCREDITATION OF PSYCHIATRIC FACILITIES, May 26-28, Ottawa. Info: Carolyn Belzile, School of health administration, University of Ottawa, Ottawa KiN 6N5. Day In therapeutics, MANAGEMENT OF THE OLDER PATIENT, Sarnia, Ont. Info: Ontario Medical Foundation, 242 St. George St., Toronto M5R 2P4. CANADIAN SOCIETY OF PLASTIC SURGEONS, May 28-31, Toronto. Info: Dr. H.J. Shimlzu, #4308409 112 St. Edmonton, T6G 1K6
June NEWFOUNDLAND MEDICAL ASSOCIATION, June 4-7, Gander. Info: G. Lynch, NMA, OMara-Martin Bldg., Rawlins Cross, St. Johns, Nfld. International symposium, CHILD WITH CONGENITAL HEART DISEASE AFTER SURGERY, June 5-7, Inn on the Park Hotel, Toronto. Info: Ontario Heart Foundation, Professional education, 310 Davenport Rd., Toronto M5R 3K2. Combined centennial meetings, CANADIAN PAEDIATRIC SOCIETY, SOCIETY FOR ADOLESCENT MEDICINE, AMBULATORY PAEDIATRIC ASSOCIATION, HOSPITAL FOR SICK CHILDREN ALUMNI, June 7-12, Toronto. Info: Dr. J.W. Balfe, Nephrology dept., Hospital for Sick Children, Toronto, Ont. Seminar, CONFLICTS IN THE PHYSICAL REHABILITATION TEAM, June 9-10, Ottawa. Info: Carolyn Beizile, School of Health AdminIstration, University of Ottawa, Ottawa KiN 6N5. Annual meeting, CANADIAN CANCER SOCIETY, June 13, GeorgIa Hotel, Vancouver. Info: Alan MartIn, Canadian Cancer Society, 25 AdelaIde St. E, Toronto M5C 1Y2.
INTERNATIONAL CHILDBIRTH EDUCATION ASSO. CIATION, May 20-23, HamIlton, Ont. Info: Lynn Gilbank, ICEA Canadian Conference, 149 Woodview Cres., Ancaster, Ont. L9G iGi.
Seminar, HEALTH ADMINISTRATION RESEARCH FORUM, June 16-17, Ottawa. Info: Carolyn Beizile, School of health administration, University of Ottawa, Ottawa KiN 6N5.
CANADIAN ORTHOPAEDIC ASSOCIATION, May 25-29, Ottawa. Info: Dr. R. 1. Cruess, Canadian Orthopsedlc Assn., 5470 Oueen Mary Rd., Suite 1, Montreal 248, P.O.
10th CanadIan Congress of .4EUROLOGICAL SCIENCES, June 18-21, London. Info: Dr. A. J. Hudson, University Hospital, 339 Wlndermere Road, London N6G 2K3
1004 CMA JOURNAL/APRIL 19, 1975/VOL 112
