Does the parol evidence rule apply to the construction of Indian treaties?

36. The parol evidence rule has its analogy in the approaches to the construction of Indian treaties. This Court in Simon v. The Queen, 1985 CanLII 11 (SCC), [1985] 2 S.C.R. 387, was concerned with the proper interpretation of an Indian treaty by the courts. Dickson C.J. stated at p. 404: "An Indian treaty is unique; it is an agreement sui generis which is neither created nor terminated according to the rules of international law". An early judgment in Nowegijick v. The Queen, 1983 CanLII 18 (SCC), [1983] 1 S.C.R. 29, referred more broadly to the rules of interpretation properly applicable in a court of law to an Indian treaty. Dickson J. (as he then was) there stated, at p. 36: "... treaties and statutes relating to Indians should be liberally construed and doubtful expressions resolved in favour of the Indians".