Estoppel - Obiter Dicta. Canada (Public Safety and Emergency Preparedness) v. Gaytan
In Canada (Public Safety and Emergency Preparedness) v. Gaytan (Fed CA, 2021) the Federal Court of Appeal comments on obiter dicta:
 In an oft-quoted passage from R. v. Henry, 2005 SCC 76,  3 S.C.R. 609 (Henry), the Supreme Court of Canada stated that the weight of obiter "“decreases as one moves from the dispositive ratio decidendi to a wider circle of analysis which is obviously intended for guidance and which should be accepted as authoritative”" and that beyond the wider circle of analysis there will be non-binding "“commentary, examples or exposition that are intended to be helpful and may be found to be persuasive”" (Henry at para. 57). In other words, obiter dicta move along a continuum (R. v. Prokofiew, 2010 ONCA 423, 100 O.R. (3d) 401 at para. 20, aff’d without reference to this point, 2012 SCC 49,  2 S.C.R. 639).