Mr. Shime in his factum pointed out that the Charter must be construed liberally in order to protect the citizen against government encroachment. Moreover, the privacy rights of an individual may be protected by the Charter: See R. v. Dyment, 1988 CanLII 10 (SCC), [1988] 2 S.C.R. 417, [1988] S.C.J. No. 82, at pp. 426 and 428-29 S.C.R. The reputation of a person is also something which "underlies all the Charter rights": see Hill v. Church of Scientology of Toronto (1995), 1995 CanLII 59 (SCC), 24 O.R. (3d) 865, [1995] 2 S.C.R. 1130, [1995] S.C.J. No. 64, at paras. 120 and 121.
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