There is no requirement that the provisions be identical, and their wording is not a determinative factor. It is sufficient that the essential elements of the offence committed abroad are similar to those of the offence under Canadian law. Additionally, the Honourable Justice Urie in Hill v. Canada[5] made the following remarks: … equivalency can be determined in three ways: - first, by a comparison of the precise wording in each statute both through documents and, if available, through the evidence of an expert or experts in the foreign law and determining there from the essential ingredients of the respective offences. Two, by examining the evidence adduced before the adjudicator, both oral and documentary, to ascertain whether or not that evidence was sufficient to establish that the essential ingredients of the offence in Canada had been proven in the foreign proceedings, whether precisely described in the initiating documents or in the statutory provisions in the same words or not. Third, by a combination of one and two.
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