What is the difference between primary, secondary and tertiary grounds?
Alberta, Canada
The following excerpt is from United States v. Yuen, 2004 ABCA 368 (CanLII):
With respect to the secondary issue, the chambers judge does state that he is considering the case of Canada v. Pitman, [1986] O.J. No. 273 on the question of primary, secondary and tertiary grounds. Again, I am not satisfied that he overlooked the need to address the secondary and tertiary grounds.
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