Editing Blasphemous libel (section)

===Last prosecution: ''R v Rahard'' (1935)===
The last prosecution of a charge of blasphemous libel was in 1935, in ''R v Rahard'', in Quebec.<ref>''R v Rahard'', [1936] 3 D.L.R. 230 (Court of Sessions of the Peace, Quebec, 1935).</ref> In that case, the court adopted an argument that prosecutor E. J. Murphy had proffered in the case of ''R v Sperry'' (unreported) in 1926. Mr. Murphy put the issue this way:

{{quote|The question is, is the language used calculated and intended to insult the feelings of and the deepest religious convictions of the great majority of the persons amongst whom we live?  If so, they are not to be tolerated any more than any other nuisance is tolerated. We must not do things that are outrages to the general feeling of propriety among the persons amongst whom we live.<ref>48 ''Canadian Criminal Cases'' 1.</ref>}}

In ''Rahard'', the Court found the Rev. Victor Rahard of the [[Anglican Church of Canada]] guilty of blasphemous libel for his aspersions upon the Roman Catholic Church.<ref>The information on blasphemous libel in Canada comes from ''Tremeear's Annotated Criminal Code'' (published annually).</ref>

The words "calculated and intended to insult the feelings and the deepest religious convictions of the great majority of the persons amongst whom we live", which the court used, were adopted from the summing up of Lord Coleridge, LCJ. in ''R v Bradlaugh''.<ref>''R v Bradlaugh'' (1883), 15 [[Cox's Criminal Cases|Cox CC]] 217 at 230.  The court also cited ''R. v St Martin'' (1933), 40 Rev. de Jur. 411.  ''Cf''. ''R v Kinler'' (1925). 63 Que. S.C. 483.</ref><ref>The [[Law Commission (England and Wales)|Law Commission]]. Offences against Religion and Public Worship. Working paper no. 79. 1981. para. 4.7 and note 181 at p. 46</ref>