We do not overlook that the cases just cited were concerned with the
scope of questions that might be put to witnesses under compulsory
powers given by statute. They were not directly concerned with the scope
of findings in reports. But if the Court has jurisdiction to determine
the true scope of a Commission's inquiry and require the Commission to
keep within that scope there are obvious arguments that it should have a
corresponding jurisdiction in the matter of findings. A vital part of
the constitutional role of the Courts is to ensure that all public
authorities, whether they derive their powers from statute or the
prerogative, act within the limits of those powers.

A different view was taken by Stephen J. sitting at first instance in
chambers in _R._ v. _Collins_ (1976) 8 A.L.R. 691, but we note the
opinion expressed in several Canadian cases that the Court will
intervene where a Commissioner has inquired or seeks to inquire into
matters outside his terms of reference: _Re Sedlmayr_ (1978) 82 D.L.R.
(3d.) 161; _Re Anderson_ (1978) 82 D.L.R. (3d.) 706; _Landreville_ v.
_The Queen_ (1973) 41 D.L.R. (3d.) 574; _Landreville_ v. _The Queen_
(No. 2) (1977) 75 D.L.R. (3d.) 380, 400-402.

In _Re Royal Commission on Thomas Case_ (1980) 1 N.Z.L.R. 602 a Full
Court (Molier, Holland and Thorp JJ.) held inter alia that the Court may
prohibit a Commission from acting in excess of its jurisdiction and that
the creation of a Commission pursuant to the Letters Patent does not
exempt it from the supervisory role of the Court. However part of the
Full Court's decision in that case is the subject of a pending appeal to
this Court and other proceedings relating to the Thomas Commission have
been moved into this Court. So we refrain from expressing any final view
upon it.