The question frequently arises in prison related matters as to whether or not any statements or evidence given by a prisoner or parolee before various boards and tribunals affecting their existence, are admissible in subsequent criminal proceedings, or alternatively, whether or not evidence given in criminal proceedings might be admissible against them in subsequent prison or parole related proceedings. It should be noted that the protection is given to the witness who testifies in specific proceedings so that any evidence that incriminates that witness cannot be used against that witness in other proceedings, except in a prosecution for perjury or for the giving of contradictory evidence. The evidence given by other witnesses in criminal proceedings and indeed the evidence of the accused as a witness in criminal proceedings is frequently referred to or considered by prison and parole authorities in relation to subsequent decisions that have to be made affecting that accused witness throughout the course of their sentence. It is the converse situation involving a person who is compelled or otherwise feels obliged to make statements in disciplinary or parole suspension proceedings and is facing or who might face subsequent criminal proceedings that gives greater cause for concern. This issue has been addressed in relation to post suspension parole hearings in R v Carlson. In Carlson, the court in criminal proceedings held that by virtue of s13 of the Charter, the Crown could not lead in evidence in the criminal proceedings for manslaughter, statements made by the accused parolee at the post suspension hearing, even if the parolee was advised of his right to an assistant and it was made clear to him that he was not obliged to say anything regarding any outstanding charges at the post suspension hearing. The courts gave s13 of the Charter a broad and liberal interpretation and held that a parole hearing is a "proceeding" and that the statements made by the parolee are made as a "witness" even though such statements are not given under oath. The court said that though the word "testifies" usually signifies sworn evidence before a tribunal or officially constituted public body, that nevertheless the absence of an oath in the circumstances was not determinative as the accused parolee did appear before an officially constituted public body where he was required to assert his position and the consequences to him would be of great significance. The same issue does not appear to have arisen as yet in relation to disciplinary court proceedings inside prisons, although it has arisen in relation to the disciplinary proceedings of others, such as the legal profession. In Donald v Law Society of British Columbia, the testimony of a lawyer defending a civil defamation suit was later admitted into evidence in disciplinary proceedings against him by the Law Society who found him guilty of professional misconduct. On appeal, the court held that the evidence incriminating him in the civil defamation proceedings could not be used in the subsequent disciplinary proceedings and that the words "any other proceedings" in s13 of the Charter would include any proceeding where one is exposed to a criminal charge, penalty or forfeiture.