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A-80-77
S.E.A.P. (Save the Environment from Atomic Pol lution) (Applicant)
v.
Atomic Energy Control Board and Eldorado Nuclear Limited (Respondents)
Court of Appeal, Urie J., MacKay and Kerr D.JJ.—Toronto, March 15 and 18, 1977.
Judicial review — Application to set aside decision of Atomic Energy Control Board licensing Eldorado Nuclear Limited to use Port Granby Residue Area for storing radioac
tive substances Whether Board's decision administrative or
judicial in nature Function of Board — Application dis
missed, as Board's decision is strictly administrative — Atomic Energy Control Act, R.S.C. 1970, c. A-19, ss. 3(1), 7, 8 and 9 Federal Court Act, s. 28.
JUDICIAL review. COUNSEL:
D. Estrin for applicant.
W. I. C. Binnie and G. R. Strathy for
respondent Atomic Energy Control Board.
P. Y. Atkinson for respondent Eldorado Nuclear Limited.
SOLICITORS:
D. Estrin, Toronto, for applicant.
McTaggart, Potts, Stone & Herridge, Toronto, for respondent Atomic Energy Con trol Board.
Aird, Zimmerman & Berlis, Toronto, for respondent Eldorado Nuclear Limited.
The following are the reasons for judgment of the Court delivered orally in English by
KERR D.J.: S.E.A.P. filed an originating notice, dated February 9, 1977, of an application under section 28 of the Federal Court Act to review and set aside a decision, dated January 31, 1977, of the respondent Atomic Energy Control Board (which I shall refer to as "the Board"), which authorized or granted a licence to the respondent Eldorado Nuclear Limited (which I shall refer to as "Eldorado") to continue to use the Port Granby
Residue Area for purposes of storage of radioac tive prescribed substances, subject to certain terms and conditions specified in the licence. The licence was to expire on July 31, 1977, unless amended.
Eldorado filed a motion to quash that section 28 application of S.E.A.P. Counsel for S.E.A.P. asked that the hearing of the motion to quash be adjourned pending the hearing of the section 28 application on its merits. We had grave doubt as to this Court's jurisdiction in respect of that section 28 application, and we decided to proceed to hear Eldorado's motion to quash.
We heard the submissions of counsel for Eldorado and counsel for the Board on Tuesday, March 15, 1977, and then adjourned the hearing until this morning to hear counsel for S.E.A.P. in reply. On the resumption of the hearing this morn ing, counsel for S.E.A.P. chose not to offer argu ment or submissions in reply on the question of the Court's jurisdiction in respect of the section 28 application. He repeated his submission that the motion to quash should not be disposed of until after the section 28 application has been dealt with on its merits.
In support of Eldorado's motion, its counsel and counsel for the Board submitted, principally,
(a) that the Board's decision is one "of an administrative nature not required by law to be made on a judicial or quasi-judicial basis;"
(b) that the Board is an "agent of the Crown" and is not a "federal board, commission or other tribunal" within the meaning of those words as used in section 28 of the Federal Court Act, there being no mention of the "Crown" in that section; and
(c) that S.E.A.P. has no status or entitlement to bring its section 28 application.
It is clear that, if the Board's said decision is a "decision or order of an administrative nature not required by law to be made on a judicial or quasi-judicial basis" within the meaning of the said section 28, this Court has no jurisdiction to
grant the relief sought by S.E.A.P., and the application to quash should be granted.
In order to determine whether the Board's deci sion is one that was not required by law to be made on a judicial or quasi-judicial basis it is necessary to look particularly, but not necessarily exclusively, to the Atomic Energy Control Act', which established the Board, to see what the Board's functions are and how they are to be exercised.
The preamble in that Act reads as follows:
WHEREAS it is essential in the national interest to make provision for the control and supervision of the development, application and use of atomic energy, and to enable Canada to participate effectively in measures of international control of atomic energy which may hereafter be agreed upon;....
Certain other provisions of that Act are also relevant, including the following:
Section 3(1) provides that the Board's powers are exercisable by it only as an agent of Her Majesty.
Section 7 provides that the Board shall comply with any general or special direction given by the Minister with reference to the carrying out of its duties.
Section 8 provides that the Board may make rules for regulating its proceedings and the performance of its duties; and, by paragraph (d) of that section, it may, with the approval of the Minister, disseminate or provide for the dissemi nation of information relating to atomic energy to such extent and in such manner as the Board may deem to be in the public interest.
Section 9 gives the Board power to make, with the approval of the Governor in Council, certain regulations; and pursuant to that power the Board made the Atomic Energy Control Regu lations. Sections 7 and 9 of those Regulations provide for issuing licences upon receipt of a written application from the person requiring a licence, which application shall set forth infor mation required by the Board, including infor mation necessary to evaluate the application; and a licence issued by the Board may contain
' R.S.C. 1970, c. A-19.
such conditions as the Board deems necessary in the interests of health, safety and security. Section 27 of the Regulations provides proce dures related to revocation, suspension or amendment of a licence, including notice in writing to the holder and the giving of informa tion in writing of the reasons for the revocation, etc., to the holder and the giving of a reasonable opportunity to be heard by the Board after receiving the said information.
There do not appear to be similar or any provi sions in the Act or Regulations requiring the Board, on an application for a licence, to sit in public, hold a hearing, give notice of the applica tion, or follow or adopt procedures analogous to the judicial.
We have concluded that the decision of the Board that S.E.A.P. seeks to have set aside is a decision of an administrative nature not required by law to be made on a judicial or quasi-judicial basis, and consequently that this Court has no jurisdiction to grant the relief sought by S.E.A.P. in its section 28 application. Therefore, the application of Eldorado to quash the section 28 application should be granted.
Having regard to our said conclusion it is not necessary for the disposition of the matter to make a definitive determination of Eldorado's contention that, because the Board is an agent of the Crown and the Crown is not mentioned in section 28 of the Federal Court Act, the Board is not a "board, commission or other tribunal" within the meaning of that section. However, it appears to us that the contention is without merit.
It is also not clear to us, on what has been presented, that S.E.A.P. has an entitlement to bring its section 28 application, but it is not neces sary, having regard to our disposition of the matter, to explore further the question of entitlement.
The section 28 application will be quashed.
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