The Greulich and Pyle wrist X-ray method does not provide reliable evidence of whether a person is over or under 18 years of age and cannot be used as the sole basis for establishing jurisdiction in people smuggling cases. Where the Crown bears the onus of proving the accused was 18 or older to establish District Court jurisdiction, evidence from family members with personal knowledge of the accused's birth may be accepted to establish the accused's age on the balance of probabilities. The court left open whether, where an accused withdraws a jurisdictional objection and pleads guilty while in possession of exculpatory evidence, the accused must positively establish the jurisdictional fact on a subsequent referral rather than merely cast doubt on it.
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