What constitutes the practice of law in the context of a non-lawyer holding himself out to be an agent?

In Nixon v. Newfoundland, the court considered what constituted the practice of law or the unlawful practice of law in the context of a non-lawyer holding himself out to be an agent. That case turned on the interpretation of the “practice of law” under the Newfoundland Law Society Act. Puddester J. held that for the purposes of the Newfoundland Law Society Act, “practice of law” should be defined without reference to whether it is for gain or reward, but under the Act itself, gain or reward is relevant as to whether the practice is “active”. (At para. 165).