In Black v. Chretien, the Ontario Court of Appeal addressed the issue of the courts' ability to review the exercise of Crown prerogative powers. While the court held that the exercise of prerogative powers is subject to judicial review in general, it stipulated that certain categories of prerogative powers are not reviewable. The court reasoned that judicial review is limited to instances where the nature and subject matter of the prerogative powers are amenable to the judicial process. In Conrad Black's lawsuit against the prime minister, the court round that the communication between the prime minister and the Queen represented an exercise of the prerogative to grant honours and that such a prerogative was non-justiciable. The author is critical of the court's use of the doctrine of justiciability to shield executive officials from judicial review. He argues that the court adopted an undesirably formalistic approach to justiciability, with the consequence that a significant sphere of executive action lies beyond the reach of the rule of law. The author maintains that justiciability should solely depend on the legitimacy and capacity of the courts to adjudicate a matter. In his opinion, Black's claim against the prime minister was justiciable.