Does the proximity test apply to an allegation of false representation?

30. In Detering v. The Queen, 1982 CanLII 59 (SCC), [1982] 2 S.C.R. 583, which involved a conviction for attempted fraud, Laskin C.J. raised a question, as I read his reasons, as to the weight to be given to the proximity test in the essential task under s. 24 of the Code of distinguishing between preparation and attempt. With reference to the contention of counsel that "proximity was an essential requirement in the sense, to put it generally, that the actions of the accused must go beyond mere preparation and close (a question of degree) to the realization of his purpose", Laskin C.J. said at p. 586: This leaves for consideration the so‑called proximity principle. It may well be that this is envisaged by the reference to remoteness in s. 24(2), but I do not see that it advances the essential issue in attempt which requires going beyond mere preparation. Nor do I find cogency in the appellant's submission that if there is impossibility this does not bring any act of the accused closer to realization so as to establish proximity. I read s. 24(1) as making a different distinction, one merely requiring proof of intent and of accused going beyond mere preparation by making, as in this case, a false representation even though not resulting in full realization of his objective.