What is the current state of the law in the context of the Charter of Canada?

In an early Charter case, Law Society of Upper Canada v. Skapinker, 1984 CanLII 3 (SCC), [1984] 1 S.C.R. 357, 9 D.L.R. (4th) 161 (S.C.C.), it was suggested that a court should not make constitutional decision if the case can be resolved on other grounds. At 383, Estey J. observed: The development of the Charter, as it takes its place in our constitutional law, must necessarily be a careful process. Where issues do not compel commentary on these new Charter provisions, none should be undertaken.