King's 1912 book on criminal libel in Canada devotes several pages to blasphemous libel. King relies heavily on British caselaw, especially the 1883 case Ramsey & Foote, which contained Coleridge's classic statement that "if the decencies of controversy are observed, even the fundamentals of religion may be attacked without a person being guilty of blasphemous libel." King also discusses Stephen's critique of that view and his argument that even a tasteful denial of Christ's divinity could be punished under British common law.
Looking at Canada's Criminal Code in light of the debate, King concludes that "[t]he declaration in the Code, as to what is not a blasphemous libel, represents the more tolerant view of the law, comparatively speaking, as expounded in the latests leading English cases." (p. 16) Interestingly, King states that "no case was to be found in the books of Ontario of an indictment for blasphemy . . . and we believe this is true of the other provinces." (p. 24) This overlooks the R. v. Pelletier case reported in 1901 (6 R.L.(n.s.) 116 Q.c.). Although King believed there were no reported prosecutions for blasphemy in Canada available for discussion, he does devote substantial space to two cases that dealt with blasphemy in a more indirect fashion: Pringle v. Napanee (1878) and Boucher v. Shewan (1864).