James v. The Queen, 84 DTC 6570, [1984] CTC 672 (S.C.O.), rev'd by 86 DTC 6432, [1986] 2 CTC 288 (Ont CA), briefly aff'd by 88 DTC 6273, [1988] 2 CTC 1, [1988] 1 SCR 669 -- summary under Subsection 244(4)

S.244(4) "leaves it entirely in the hands of the Minister to state when in his 'opinion' sufficient information was brought to his knowledge to justify prosecution. His opinion is in no way limited or fettered by the words of this section. There is no specific requirement that he have 'reasonable and probable cause' for the prosecution ... . There is ... no good reason to hold in this case in the absence of fraud, that the certificate of the Minister should not be admitted in evidence on the issue of the limitation period."