Formal demand to the Attorneys General of Ontario and Canada. Five specific demands. 30-day response window.
The instrument
Gazette No. 66 — Demand of the Attorney General
April 2026
Gazette No.: GZT001-260312-000066
Register Entry No.: REG001-020000-000066
Tracking Code: AG1212-020000-000066 Status: 13 — Provisional → Perfected / Entered / Fully Effected / Registered and Published
Category / Class: Category 03 — Justice Services · Class 12 — Demand and Direction
Demand of the Attorney General
To the Attorneys General of Ontario and Canada · Enforcement of Constitutional Obligations
Be it known to all whom it may concern:
I, Patrick Doolittle UE, Attorney General of the Mohawk Nation of Grand River Secretariat (attested by Gazette No. 5, GZT001-260101-000005), hereby issue this Demand and Direction to the Attorneys General of Ontario and Canada pursuant to the constitutional obligations set out herein. This Demand is issued with the concurrence of the Secretary-General, Benjamin Doolittle UE.
I. Authority of This Demand
(i) The authority of the office of Attorney General of the Mohawk Nation of Grand River, attested by Gazette No. 5 (GZT001-260101-000005);
(ii) The governing authority of the Secretariat, constituted nunc pro tunc 25 October 1784 and formally registered 28 March 2026;
(iii) The Haldimand instruments of 1779–1796, constituting the Crown’s solemn and unextinguished covenant obligations to the Mohawk Nation of Grand River;
(iv) Section 109 of the Constitution Act, 1867, as set out in the Notice of Constitutional Encumbrance (G65, GZT001-260204-000065);
(v) The constitutional duty of attorneys general, arising from their Oath of Office and Oath of Allegiance, to advise the Crown on its constitutional obligations and to give effect to the full constitutional order (McAteer v. Canada (Attorney General), 2014 ONCA 578).
II. Grounds
The Crown’s constitutional obligations under the Haldimand instruments are unextinguished. Section 109 of the Constitution Act, 1867 preserved the Mohawk Crown covenant interest at Confederation. Crown grants issued out of the Haldimand Tract purporting to convey fee simple free of that interest are void ab initio by operation of s. 52 (Reference re Manitoba Language Rights [1985] 1 SCR 721; Ontario Mining Co. v. Seybold [1903] AC 73). Ontario’s Director of Land Registry Services Branch has acknowledged the administrative notice gap while declining to deny the validity of the Mohawk interest. The current practice of private First Nations Claims disclaimers in Brantford land transactions (following Kingspan Insulated Panels Ltd. v. Brantford (City), 2010 ONSC 4610) does not constitute public notice and does not discharge the Crown’s constitutional obligations.
III. The Demands
1. Constitutional Advice. That each Attorney General provide, within thirty (30) days of receipt of this Demand, written constitutional advice to their respective governments acknowledging: (a) that s. 109 preserved the Mohawk Crown covenant interest at Confederation; (b) the continuing obligations under the Haldimand instruments; and (c) the implications for Land Titles Act administration.
2. Administrative Notice Mechanism. That the Attorney General of Ontario advise the Ministry of Public and Business Service Delivery to establish, within sixty (60) days, an indexed external notice record for Haldimand Tract lands identified through the Grand River Location Determination Rules (G51), recording that the parcel register’s silence is not conclusive of the interest’s non-existence.
3. Cessation of Defective Grants. That the Attorney General of Ontario advise that Crown grants and development approvals on Haldimand Tract lands should not be issued without either Mohawk concurrence or a notation acknowledging the constitutional encumbrance.
4. Federal Crown Accounting. That the Attorney General of Canada advise the federal Crown to initiate accounting for outstanding Haldimand obligations, including the Haldimand Lands Trust Account (G25) and the Schedule of Unjust Enrichment (G61, ~$2.96 trillion CAD).
5. Direct Engagement. That each Attorney General, or a senior designate with authority to negotiate, engage directly with the Attorney General of the Mohawk Nation of Grand River within thirty (30) days of receipt to establish a working protocol for resolution of the issues identified herein.
6. Written Response. That each Attorney General provide a substantive written response within thirty (30) days addressed to attorney.general@mohawkgrandriver.org and secretary.general@mohawkgrandriver.org. A response acknowledging receipt but deferring substance will not constitute compliance.
IV. Consequence of Non-Response
The mandamus application (G63) is prepared and held at status 13 (Provisional). If no substantive response is received within thirty (30) days, or if the response does not address the matters set out in Section III, the Secretariat will advance G63 to status 14 (Issued) and proceed to file with the Superior Court of Justice without further notice. The record of this Demand and all responses or non-responses will be entered in the External Correspondence Record (G30) and will form part of the evidence filed in support of the Application.
The Secretariat’s preferred outcome is a working protocol that resolves the administrative notice gap without litigation. The issuance of this Demand is made in that expectation.
Cross-References
GZT001-260101-000005 G5 · Attestation: Attorney General
GZT001-010300-000032 [now GZT001-260204-000032] G30 · External Correspondence Record
GZT001-260606-000025 G25 · Haldimand Lands Trust Account
GZT001-050400-000061 [now GZT001-260609-000061] G61 · Schedule of Unjust Enrichment
GZT001-260310-000063 G63 · Application for Writ of Mandamus (Provisional)
GZT001-260311-000064 [now GZT001-260310-000064] G64 · Memorandum of Fact and Law (Provisional)
GZT001-260204-000065 G65 · Notice of Constitutional Encumbrance, s. 109
Execution
Nothing in this Demand is to be taken as any limitation or waiver of the constitutional rights, claims, remedies, or interests of the Mohawk Nation of Grand River, all of which are expressly reserved.
Patrick Doolittle UE · Attorney General
Attorney General
Date
Concurred by:
Benjamin Doolittle UE · Secretary-General
Secretary-General · Concurrence
Date
Certification of the Registrar General
I certify that this instrument has been duly received, examined, and entered in the Register of the Nation of the Mohawk Nation of Grand River Secretariat.
Gazette No.: GZT001-260312-000066
Register Entry No.: REG001-020000-000066
Jesse Butler UE · Registrar General
Registrar General
Date of Registration
This instrument forms part of the permanent record of the Secretariat.
Mohawk Nation of Grand River · Grand River Territory
