588 THE ADVOCATE
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ENDNOTES
1. (1972), 32 DLR (3d) 443 (BCSC). See also Ian Waddell,
“The Consumer Class Action“ (2014) 72 Advocate
513 – Asst. Ed.
2. Waddell v Governor in Council (1983), 5 DLR (4th)
254 (BCSC). The case, argued before Lysyk J, has
been cited dozens of times, most recently by the
Supreme Court of Canada, just days after Ian died,
in Reference re Greenhouse Gas Pollution Pricing
Act, 2021 SCC 11. The “Henry VIII clause” was
described by Lysyk J as one in which Parliament confers
upon its delegate power to amend the delegating
statute, or another statute: “The nickname derives
from the popular view of that King as the personification
of executive autocracy and one whose purpose
was to enlarge his powers to make
proclamations having the force of law”.