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VULNERABLE130 general act that applies to all municipalities, and retain the power to override local decisions. Many larger cities, such as Montréal, have been granted more expansive powers, including more options for raising revenue and greater oversight in such matters as infrastructure and housing.4 In addition to municipal acts, numerous other pieces of legislation enable local governments.5 Legislation may also empower such bodies as health authorities or school boards, which overlap with municipal power. Municipalities must act within jurisdictional limits or courts will “quash municipal action as ultra vires, or beyond its legal competence.”6 The notion of cities as “creatures of the province” was articulated by the Ontario Superior Court in East  York  v  Ontario  (AG), a challenge to the unilateral amalgamation of six municipalities into the “megacity” of Toronto, which set out four principles regarding the constitutional status of municipalities: (i) municipal institutions lack constitutional status; (ii) municipal institutions are creatures of the legislature and exist only if provincial legislation so provides; (iii) municipal institutions have no independent autonomy and their pow- ers are subject to abolition or repeal by provincial legislation; and (iv) municipal institutions may exercise only those powers which are con- ferred upon them by statute.7 Despite these purportedly blunt lines of authority set out in the constitution, the SCC has acknowledged numerous times that munici- palities are democratic governments that represent their residents.8 The SCC has carved out a distinct role for local democracies, with municipal decisions almost always judicially reviewed on a standard (City)  v  Rascal  Trucking  Ltd, 2000 SCC 13; 114957  Canada  Ltée  (Spraytech,  Société  d’arrosage)  v  Hudson  (Town), 2001 SCC 40 [Spraytech]. 4. See e.g. Municipal  Government  Act, RSO 1990, c M-26; Charter of Ville de Montréal, RSO 2000, c 56, Schedule I, c C-11.4; City  of  Toronto  Act,  2006, SO 2006, c 11, Schedule A at s 1(1). 5. See e.g. Planning  Act, RSO 1990, c P.13 and Municipal  Conflict  of  Interest  Act,  RSO 1990, c M.50, which apply to all Ontario municipalities. 6. Stanley Makuch, Neil Craik & Signe B Leisk, Canadian  Municipal  and  Planning  Law (Toronto: Thomson Carswell, 2004) at 81. 7. East  York  v  Ontario  (AG) (1997), 34 OR (3d) 789, 76 ACWS (3d) 1020 (Gen Div); aff’d (1997), 36 OR (3d) 733, 153 DLR (4th) 299 (CA); leave to appeal to SCC refused ([1998] 1 SCR vii at 797-98), see Supreme Court of Canada, “Bulletin of April 9, 1998” (1998), online: Supreme Court of Canada <https://decisions.scc-csc. ca/scc-csc/bulletins/en/item/166/index.do?q=east+york+%28borough%29>. 8. See e.g. Pacific  National  Investment  Ltd  v  Victoria  (City), 2000 SCC 64, reconsidera- tion/rehearing refused.