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National Indian Brotherhood, Indian-Eskimo Association, Union of Ontario Indians and Canadian-Indian Centre of Toronto (Applicants)
v.
Pierre Juneau, H. J. Boyle, Mrs. P. Pearce, Hal Dornan, R. Therrien, and Canadian Radio- Television Commission (Respondents)
No. 2
Court of Appeal, Jackett C.J.—Toronto, June 21, 1971.
Jurisdiction—Motion to set aside decision of CRTC refus ing public hearing of complaint against telecast—Decision made before Federal Court Act proclaimed—Whether Court of Appeal has jurisdiction—Federal Court Act, secs. 28, 52(a)—Federal Court Rule 1100—Broadcasting Act, 1967- 68 (Can.), c. 25, s. 19(2)(c).
On May 28, 1971, the Executive Committee of the CRTC, not being satisfied that it would be in the public interest to do so, decided not to hold a public hearing into a complaint by four associations against the telecast of a film alleged to be slanderous of Indians. On June 7 the four associations applied to the Trial Division under s. 18 of the Federal Court Act for writs of mandamus and certiorari to compel a public hearing of their complaint under s. 19 (2)(c) of the Broadcasting Act, 1967-68, c. 25. On the same day applicants also applied to the Court of Appeal under s. 28 of the Federal Court Act to set aside the CRTC order of May 28 for failure to observe the principles of natural justice, etc.
The applicants moved for directions under Federal Court Rule 1403 with respect to their application to the Federal Court to set aside the CRTC order of May 28, 1971. The application was heard by the Chief Justice.
Held, the motion for directions should be adjourned until the Court of Appeal decided whether it had jurisdiction in the matter in view of the terms of s. 61(1) of the Federal Court Act by which the Court's jurisdiction to set aside decisions is restricted to those made after the Act came into force, viz June 1, 1971.
[Federal Court Act, 52(a) and Rule 1100 discussed].
MOTION for directions.
J. D. Kars wick for applicants.
No one for respondents.
JACKETT, C.J. (orally)—This is an application for directions in connection with a proceeding
that commenced in this Court by a "Notice of Application" filed on June 7, 1971.
That "Notice of Application" reads as follows:
TAKE NOTICE of the application to the Court of Appeal to review and set aside the decision or order of the Execu tive Committee that the Canadian Radio-Television Com mission made on May 28, 1971, on the grounds that the Executive Committee and its individual members:
(a) failed to observe the principles of natural justice by denying the Applicants the right to a fair hearing and the protection of the law;
(b) erred in law by failing to permit the Applicants the right to a hearing, the protection of the law, and misinter preting and misapplying the provisions of the Broadcast ing Act;
(c) based their decision on an erroneous finding of fact by deciding that the CTV Television Network were will ing to meet to discuss the programme, "The Taming of the Canadian West".
AND TAKE NOTICE that the Applicants will request the Court to decide this issue on such further and other grounds as may be allowed.
The decision referred to in that application is a decision of the Executive Committee of the Canadian Radio-Television Commission that is reflected in a "telex" message dated May 28, 1971, from Pierre Juneau, Chairman of that Commission, to James D. Karswick, who is solicitor for the applicants. That message reads as follows:
ACCORDING TO WELL ESTABLISHED PRACTICE AND TRADITION IN BROADCASTING IN CANADA, THE LICENSEE OF A BROADCASTING UNDER TAKING IS RESPONSIBLE FOR THE PRO GRAMMES HE BROADCASTS. THIS POLICY IS REITERATED IN SECTION 2 OF THE 1968 BROAD CASTING ACT.
THE COMMISSION FIRMLY BELIEVES THAT THIS POLICY IS OF VITAL IMPORTANCE TO THE MAINTENANCE OF THE RIGHT TO FREEDOM OF EXPRESSION IN THE CANADIAN BROADCASTING SYSTEM. A DECISION TO SUSPEND THE BROAD CAST OF A PROGRAMME OR TO CONDUCT AN INVESTIGATION INTO A SINGLE PROGRAMME SUCH AS THE TAMING OF THE CANADIAN WEST IS A MOST SERIOUS ONE.
YOUR LETTER OF MAY 21, 1971 IS THE FIRST NOTICE TO THE CRTC THAT YOU WISH THE COMPLAINTS OF YOUR CLIENTS TO BE CONSID ERED UNDER SECTION 19 OF THE BROADCAST ING ACT AT A PUBLIC HEARING. IN LIGHT OF
THE MATTERS RAISED ABOVE, AND THE WILL INGNESS EXPRESSED BY CTV TO MEET TO DIS CUSS THE PROGRAMME, THE EXECUTIVE COM MITTEE IS NOT SATISFIED THAT IT WOULD BE IN THE PUBLIC INTEREST TO HOLD A HEARING ON YOUR CLIENTS' COMPLAINT. THE COMMIS SION HOPES THAT YOUR CLIENTS AND THE CTV WILL PURSUE THIS MATTER AND THAT YOUR CLIENTS WILL AVAIL THEMSELVES OF THE OPPORTUNITY OFFERED TO THEM TO HAVE ANY INACCURACIES IN THE PROGRAMME COR RECTED OR SEEK OTHER SOLUTIONS WHICH COULD RESOLVE THE DIFFERENCES. COPY OF THIS TELEX SENT TO CTV.
It would appear from this that, by a letter dated May 21, 1971, Mr. Karswick requested that complaints of the applicants against a pro gramme known as "The Taming of the Canadi- an West" be considered by the Canadian Radio- Television Commission at a public hearing under s. 19(2) of the Broadcasting Act, 1967-68 (Can.), c. 25, which subsection reads, in part, as follows:
19. (2) A public hearing shall be held by the Commission, if the Executive Committee is satisfied that it would be in the public interest to hold such a hearing, in connection with
* * *
(c) a complaint by a person with respect to any matter within the powers of the Commission.
It also appears from the "telex" message of May 28, 1971, that the Executive Committee had not, at the time that that message was sent, been "satisfied that it would be in the public interest to hold a hearing" on the applicants' complaints.
This conclusion by the Executive Committee that it had not been satisfied that it would be in the public interest for the Canadian Radio- Television Commission to hold a hearing on the applicants' complaints is what this Court is being asked to review and set aside by the "Notice of Application" filed on June 7 last. That application is based on s. 28(1) of the Federal Court Act, which reads as follows:
28. (1) Notwithstanding section 18 or the provisions of any other Act, the Court of Appeal has jurisdiction to hear and determine an application to review and set aside a decision or order, other than a decision or order of an administrative nature not required by law to be made on a judicial or quasi-judicial basis, made by or in the course of
proceedings before a federal board, commission or other tribunal, upon the ground that the board, commission or tribunal
(a) failed to observe a principle of natural justice or otherwise acted beyond or refused to exercise its jurisdiction;
(b) erred in law in making its decision or order, whether or not the error appears on the face of the record; or
(c) based its decision or order on an erroneous finding of fact that it made in a perverse or capricious manner or without regard for the material before it.
While the matter that is before me today is an application for directions under Rule 1403, the effect of which would be to establish a pro gramme for the section 28 proceeding, as there is an obvious and grave doubt as to the Court's jurisdiction in the matter, I am of the view that I should not proceed with the application for directions until the question of jurisdiction has been determined.
Apart from any other problem concerning the application of s. 28(1) in the circumstances of this matter, the application is, on the face of it, an application to set aside a "decision or order" that was made on May 28, 1971, whereas s. 61(1) of the Federal Court Act provides, among other things, that "Where this Act creates . . . a right to apply to the Court of Appeal under section 28 to have a decision or order reviewed and set aside, such right applies,
in respect of a . . . decision or order given or made after this Act comes into force . . .", and the Federal Court Act was brought into force by proclamation on June 1, 1971. It follows, in my opinion, that there is no right under s. 28(1) to apply to have a "decision or order" made on May 28, 1971, reviewed and set aside and, therefore, that this Court has no jurisdiction in the present matter.
For that reason, in my opinion, and on the circumstances as I appreciate them at this moment, this proceeding should be quashed under s. 52(a) of the Federal Court Act, which reads as follows:
52. The Court of Appeal may
(a) quash proceedings in cases brought before it in which it has no jurisdiction or whenever such proceedings are not taken in good faith . . .
However, before any judgment is given quashing such a proceeding, Rule 1100 must be invoked. That rule reads as follows:
RULE 1100. (1) An application to quash proceedings under section 52(a) of the Act may be made at any time, but failure to move promptly may, in the discretion of the Court, be ground for a special order as to costs of the motion and of the proceedings.
(2) The Court of Appeal may of its own motion make an order under section 52(a) quashing proceedings after giving the appellant and any other interested party an opportunity to be heard.
In the circumstances, it would seem appropriate to adjourn this application for directions pend ing a determination of the question of jurisdic tion. I should hope that, unless the application is withdrawn, the respondents or the Deputy Attorney General of Canada will make a motion to quash, under Rule 1100(1), so as to raise the matter of jurisdiction. If no such motion is made within 10 days, and the application under s. 28 is not withdrawn, having regard to s. 28(5), which imposes a duty on the Court to hear and determine section 28 matters without delay, I anticipate that the Court will issue a direction, under Rule 1100(2), giving the parties an opportunity to be heard on the jurisdiction question. I further anticipate that the Court would consist of three judges for any hearing under Rule 1100.
That is all that I need to say to explain why I have concluded that I should adjourn this application for directions to be brought on again by the applicant forthwith after such time, if any, as the Court decides that it has jurisdiction in the section 28 proceeding. I should not, how ever, leave the matter without indicating that, in my view, there are much more difficult ques tions concerning the application of s. 28(1) than the rather simple matter of the date of the "decision or order".
Probably the most important question that has to be decided concerning the application of s. 28(1) is the question as to the meaning of the
words "decision or order". Clearly, those words apply to the decision or order that emanates from a tribunal in response to an application that has been made to it for an exercise of its powers after it has taken such steps as it decides to take for the purpose of reaching a conclusion as to what it ought to do in response to the application. I should have thought, how ever, that there is some doubt as to whether those words—i.e., decision or order—apply to the myriad of decisions or orders that the tribu nal must make in the course of the decision- making process. I have in mind decisions such as
(a) decisions as to dates of hearings,
(b) decisions on requests for adjournments,
(c) decisions concerning the order in which parties will be heard,
(d) decisions concerning admissibility of evidence,
(e) decisions on objections to questions to witnesses, and
(f) decisions on whether it will permit written or oral arguments.
Any of such decisions may well be a part of the picture in an attack made on the ultimate deci sion of the tribunal on the ground that there was not a fair hearing. If, however, an interested party has a right to come to this Court under s. 28 on the occasion of every such decision, it would seem that an instrument for delay and frustration has been put in the hands of parties who are reluctant to have a tribunal exercise its jurisdiction, which is quite inconsistent with the spirit of s. 28(5). A similar question arises where a tribunal proceeds by stages in reaching a conclusion on the ultimate matter that it has to decide (compare Smith Kline & French Inter- American Corp. v. Micro Chemicals Ltd [1968] 1 Ex.C.R. 326, at pages 326 to 330), and I have doubts that s. 28(1) authorizes an application in such a case before the ultimate decision is reached. I also have doubts as to whether a refusal by a tribunal to entertain an application or its decision to embark on an inquiry is a decision that falls within s. 28(1). It may well be that, in respect of such matters, the dividing line falls between decisions of a tribunal before it
embarks, and completes, its processing of a matter, where a party must proceed by one of the old Crown writ proceedings and build a case upon which the Court may decide whether he is entitled to relief, and decisions based on a case which has been made before the tribunal, where the Court of Appeal may base its decision on what was or was not done before the tribunal.
I do not pretend to have formulated any view as to what the words "decision or order" mean in the context of s. 28(1), but it does seem to me that what is meant is the ultimate decision or order taken or made by the tribunal under its statute and not the myriad of incidental orders or decisions that must be made in the process of getting to the ultimate disposition of a matter.
Another question that must be decided in some cases, and it seems to me that it may be raised by this application, is whether a particu lar decision or order is outside the ambit of s. 28(1) because it is a "decision or order of an administrative nature not required by law to be made on a judicial or quasi-judicial basis". A typical example of such a decision or order is a decision or order made by a minister in the process of carrying out his statutory function of managing his department. There is a question in my mind, having regard to the way s. 19 of the Broadcasting Act is formulated, as to whether that section is not making the question as to whether a particular complaint should be dealt with by "public hearing" or in some other way that complies with basic principles, one of abso lute unconditional discretion for the Executive Committee.
It must be understood that I am expressing no opinion on these questions but I am raising them so that counsel will be prepared to assist the Court on them when they arise in a particu lar matter.
It perhaps would not be inappropriate for me to say that I have had drawn to my attention a decision of Walsh J. [See National Indian Brotherhood et al. v. Juneau et al., immediately preceding this case—Ed.] concerning an application, in connection with this same matter, under s. 18 of the Federal Court Act,
and that, in my view, a judge of the Trial Division should not feel any reluctance to decide a question concerning the jurisdiction of the Court of Appeal when that question is inci dental to determining the jurisdiction of the Trial Division. He has just as much right to decide such a question when it arises before him as the Court of Appeal has when it arises in this Court.
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