Is a breach of a statutory obligation drafted to ensure the adoption of a careful method of working a “turpis causa” within the meaning of the rule?

The provinces enact laws for the regulation of such conduct of its citizens as are not malum in se --rather, they define and may penalize acts which are malum prohibitum and to which no taint of turpitude is attached in law. They also empower corporations, and I have particularly in mind municipal corporations, to enact bylaws that in like manner regulate the conduct of citizens. These are civil laws which may by their terms create or deny causes of action and give or withhold remedies according to their proper construction. It is not relevant to such considerations to inquire further whether the breach also constitutes anti-social behaviour of the kind to which the statement of Diplock L.J. was addressed. The observation of Lord Porter in National Coal Board v. England (1954) A.C. 403 at p. 419 is apposite: I cannot believe that a breach of a statutory obligation drafted to ensure the adoption of a careful method of working is a ‘turpis causa’ within the meaning of the rule. I think it is clear from the context of his statement that Lord Mansfield did not include such regulatory enactments in the positive law of which he spoke. Indeed, it may be taken that there was very little of such law at the time. It is different today. To embark on an inquiry into the applicability of the rule in all of the ramifications of conduct prohibited by provincial law or corporate bylaw would be to obscure completely the principle which is involved. I conclude that the rule has no application to provincial laws nor to bylaws.