Back in December of 2012, the of Supreme Court of Canada in Canada (Attorney General) v. Bedford, 2013 SCC 72, unanimously decided that the existing Criminal Code provisions related to prostitution were unconstitutional (i.e., they violated the Charter). In response, the Minister of Justice, Peter MacKay, introduced Bill C-36 (The Protection of Communities and Exploited Persons Act) on June 4, 2014. He characterized Bill C-36 as a "made in Canada" approach to the complex