R v Ibeagha, 2019 ACCA 1534 (per curiam):

[14] In Bigelow the court began with the general proposition that the test for finding jurisdiction in more than one territorial division is whether any element of the offence has occurred in the province claiming jurisdiction. It will be noted, however, that the factors enumerated in Bigelow do not refer expressly to an element of the offence as defined in the substantive law. They are not restricted to an element of the actus reus or the mens rea of an offence. They each refer to matters of fact that could be relevant to the proof of an essential element at trial. They include factual elements that form part of the factual narrative of the transaction in issue. If that threshold can be met, the court of more than one territorial division (or province) can assert jurisdiction and the outcome will follow the strength of the evidence.

[15] With respect to the present case, there was evidence that the scheme continued from Montreal to Alberta and back, and included the presence of the respondents. Thus jurisdiction can be found in Montreal due to the continuity of this operation. Second, the evidence in this case discloses overt acts in Quebec that are “referable to or in furtherance of a criminal plan” extending beyond Quebec. In the present case, for example, there was evidence that in Montreal the respondents received and harboured the two women, took photographs used in advertising and issued directions, received money from the women in Montreal. Third, there was evidence that the scheme at issue in the case generated effects both in Quebec and Alberta and for this reason too territorial jurisdiction could be found in the Court of Quebec.

[16] In the present case the judge did not refer to the extension of territorial jurisdiction that is recognised in the Code and elaborated in Bigelow. The omission to do so was a misapprehension of the principles of jurisdiction. The evidence of the scheme in which the respondents were involved between Montreal and Alberta, in conjunction with the breadth of the conduct defined in the offences charged, leaves no question that the Court of Quebec had jurisdiction over the three counts.