In 1982, Section 35(1) recognized aboriginal rights, stating that “the existing aboriginal and treaty rights of the aboriginal peoples of Canada are hereby recognized and affirmed”. With these rights enforced, the government had responsibilities to balance initiatives with aboriginal rights. As shown by the words “recognition and affirmation” , the government of Canada has to justify any denial of aboriginal rights, including previously denying First Nations consultation in decision-making. Since then, court cases beginning with R. v. Sparrow and later Haida Nation, Taku River Tlingit and Mikisew have been creating the new right to consultation and expanding existing ones.