Can a municipality acquire land without a by-law?

If the rule in Bernardin v. North Dufferin is truly to the effect that in all municipal by-laws in Canada the expression "may pass by-laws" is permissive in the sense contended for by Irecan, so that the council is at liberty to proceed by resolution only, there would be no rhyme or reason to the use of that expression in the Municipal Act. A simple resolution would suffice for s. 190, councils being able then to avoid the need for the commissioner's approval by not passing a by-law! In much the same way, a municipality could acquire land without a by-law pursuant to s. 184(1)(a) and, since there was no by-law, could thus avoid the requirements of s. 184(2), which states: 184(2) A by-law for the acquisition of land passed by the council of a municipality in the exercise of its powers under paragraph (1)(a) is not valid, (a) in the case of a city or town, unless the funds have been included in the detailed estimate of the anticipated expenditures of the municipality for that year; or (b) in the case of a village or hamlet, unless the by-law has been approved by the Commissioner.