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A-30-79
DeVilbiss (Canada) Limited, Phelan and Smith Limited and Waffle's Electric Limited (Appli- cants)
v.
Anti-dumping Tribunal (Respondent)
Court of Appeal, Urie, Ryan JJ. and Kelly D.J.— Toronto, June 3 and 4; Ottawa, July 20, 1982.
Anti-dumping — S. 28 application to review and set aside decision of Anti-dumping Tribunal whereby it found dumping
of certain "integral horsepower induction motors" Deputy Minister, pursuant to s. 14 of Anti-dumping Act, made pre liminary finding of dumping of "integral horsepower induction motors" as result of which inquiry scheduled before Anti- dumping Tribunal — Meaning of phrase "integral horsepower induction motors" crucial to determination of whether goods within offending class — Tribunal heard evidence regarding issue from both parties at outset of inquiry but withheld decision on meaning of phrase until conclusion of proceedings — Whether Tribunal exceeded jurisdiction in purporting to define class of goods to which preliminary determination of dumping applied — Whether Tribunal violated rules of natu ral justice by withholding decision regarding scope of inquiry
Anti-dumping Act, R.S.C. 1970, c. A-15, ss. 13(1), 14, 16(1),(3), 19, 20 — Anti-dumping Tribunal Rules of Proce dure, C.R.C., c. 300, Rule 9 — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28.
This is a section 28 application to review and set aside a decision of the Anti-dumping Tribunal wherein it was found that there had been dumping of certain integral horsepower induction motors which had caused, was causing or was likely to cause material injury to the production in Canada of like goods. In April 1978, the Deputy Minister of National Revenue for Customs and Excise authorized an investigation pursuant to subsection 13(1) of the Anti-dumping Act in respect of the dumping of integral horsepower induction motors from the United States. In October 1978, the Deputy Minister made a preliminary determination of dumping pursuant to section 14 of the Act as a result of which an inquiry was held before the Anti-dumping Tribunal. The meaning of the phrase "integral horsepower induction motors", which was crucial to the deter mination of which goods came within the offending class, was raised at the outset of the inquiry and the Tribunal received evidence from all parties but did not make its finding before it proceeded with the balance of the inquiry. The issues con sidered by the Court were whether the Tribunal, in attributing a meaning to the phrase in question, acted beyond its jurisdic tion by purporting to define the class of goods to which the preliminary determination of dumping applied and whether, by withholding its decision regarding the scope of the inquiry, the Tribunal violated the rules of natural justice.
Held, the application is granted. The jurisprudence estab lishes that the formulation of the class of goods pursuant to subsection 13(1) of the Act for the purposes of the preliminary determination is the responsibility of the Deputy Minister. When the Tribunal finds that certain dumped goods which are within the class defined by the Deputy Minister in his prelim inary determination are "like goods" to certain goods produced in Canada, it has made a finding of fact which ought not be disturbed by the Court unless there was no evidence upon which it could have been made or because a wrong principle was applied in making it. Subsection 16(1) plainly limits the Tribunal's inquiry to goods to which the preliminary determi nation applies. However where the Tribunal has difficulty in identifying the goods to which the preliminary determination applies it must try to ascertain the meaning of the words and may do so by permitting the introduction of evidence from industrial experts. This will not necessarily result in a redefini tion of the class of goods formulated by the Deputy Minister. The Tribunal did not therefore err or exceed its jurisdiction in endeavouring, in the circumstances, to determine by evidence what was meant by the words "integral horsepower induction motors". It had a duty to perform which necessarily included the interpretation of the class of goods formulated in the preliminary determination. How it achieved the interpretation was up to it to decide so long as it acted properly as a judicial or quasi-judicial body. Because the Tribunal wanted to hear evidence from all parties on the issue of the definition and to have time to consider that evidence before making a decision on its meaning the parties might reasonably have expected that they would be given an opportunity to lead evidence if the Tribunal decided that the narrower definition was the correct one. However, the Tribunal continued with the hearing without deciding what class of goods was the subject of the inquiry and its failure to make a ruling regarding the scope of the inquiry may have deprived one or more of the parties of the opportunity to lead evidence specifically directed to the class of goods the Tribunal subsequently found to be the subject of the inquiry and to controvert, correct or comment on the evidence or information relevant to the finding of the Tribunal. The failure to afford the parties such an opportunity resulted in a denial of natural justice.
CASES JUDICIALLY CONSIDERED
CONSIDERED:
Deputy Minister of National Revenue for Customs and Excise v. Trane Company of Canada, Limited, [1982] 2 F.C. 194 (C.A.).
REFERRED TO:
Magnasonic Canada Limited v. Anti-dumping Tribunal, [1972] F.C. 1239 (C.A.); Mitsui and Co. Limited et al. v. Buchanan, et al., [1972] F.C. 944 (C.A.); In re Anti- dumping Act and in re Y.K.K. Zipper Co. of Canada Ltd., [ 1975] F.C. 68 (C.A.); Remington Arms of Canada Limited v. Les Industries Valcartier Inc. et al., [1982] 1 F.C. 586 (C.A.); Sarco Canada Limited v. Anti-dumping Tribunal, et al., [ 1979] 1 F.C. 247 (C.A.); Dryden House Sales Limited, carrying on business under the firm name
and style of Ambassador-Dryden House v. Anti-dump ing Tribunal, [1980] 1 F.C. 639 (C.A.).
COUNSEL:
J. M. Coyne, Q.C. and P. S. Bonner for
applicants.
J. L. Shields for respondent.
R. P. Hynes for Attorney General of Canada.
SOLICITORS:
Herridge, Tolmie, Ottawa, for applicants.
Soloway, Wright, Houston, Greenberg, O'Grady, Morin, Ottawa, for respondent. Deputy Attorney General of Canada for Attorney General of Canada.
Tory, Tory, DesLauriers & Binnington, Toronto, for Leeson Electric (Canada) Ltd. Stitt, Baker & McKenzie, Toronto, for Reli ance Electric Ltd. and Reliance Electric Co.
The following are the reasons for judgment rendered in English by
URIE J.: This application, brought pursuant to section 28 of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, seeks to set aside the decision of the Anti-dumping Tribunal ("the Tribunal") dated January 9, 1979 in which the Tribunal found that the dumping into Canada of certain integral horsepower induction motors "has caused, is causing or is likely to cause material injury to the production in Canada of like goods".
The matter, initiated by the Deputy Minister's preliminary determination, has already been before this Court in the case of Deputy Minister of National Revenue for Customs and Excise v. Trane Company of Canada, Limited', by way of an appeal pursuant to section 20 of the Anti- dumping Act, R.S.C. 1970, c. A-15 ("the Act") from a decision of the Tariff Board which allowed an appeal by the Trane Company brought pursu ant to section 19 of the Act from a final determi-
[1982] 2 F.C. 194 (C.A.).
nation of dumping made by the Deputy Minister. The appeal from the Tariff Board was dismissed in this Court.
For consistency and accuracy in the recitation of the factual background leading to this application it is convenient to set out hereunder the following excerpt from the reasons for judgment of Le Dain J., speaking for the Court, in the Trane appeal [at pages 196-198]:
On April 6, 1978, pursuant to subsection 13(1) of the Act, the Deputy Minister of National Revenue for Customs and Excise caused an investigation to be initiated respecting the dumping into Canada of "integral horsepower induction motors, one horsepower (1 h.p.) to two hundred horsepower (200 h.p.) inclusive ... originating in or exported from the United States of America." On October 10, 1978 the Deputy Minister made a preliminary determination of dumping, pursu ant to section 14 of the Act, respecting goods described as "integral horsepower induction motors, one horsepower (1 h.p.) to two hundred horsepower (200 h.p.) inclusive, excluding vertical-shaft pump motors generally referred to as vertical P-base or vertical P-flange motors, originating in or exported from the United States of America". Following that decision an inquiry was conducted by the Anti-dumping Tribunal pursuant to subsection 16(1) of the Act, and on January 9, 1979 the following "Finding" was made by the Tribunal:
The Anti-dumping Tribunal, having conducted an inquiry under the provisions of subsection (1) of section 16 of the Anti-dumping Act, consequent upon the issue by the Deputy Minister of National Revenue, Customs and Excise of a preliminary determination of dumping dated October 10, 1978 respecting the dumping into Canada of integral horse power induction motors, one horsepower (1 h.p.) to two hundred horsepower (200 h.p.) inclusive, excluding vertical- shaft pump motors generally referred to as vertical P-base or vertical P-flange motors, originating in or exported from the United States of America, finds, pursuant to subsection (3) of section 16 of the Act, that the dumping of the above-men tioned goods, excluding:
1) single phase motors;
2) submersible pump motors for use in oil and water wells;
3) arbor saw motors; and
4) integral induction motors for use as replacement parts in
i) absorption cold generator pumps manufactured by The Trane Company,
ii) Centravac Chillers manufactured by The Trane Company, and
iii) semi-hermetic compressors and hermetic compres sors manufactured by The Trane Company,
has caused, is causing, and is likely to cause material injury to the production in Canada of like goods.
The "Statement of Reasons" which accompanied the "Find- ing" of the Tribunal contained the following discussion at pages 5 and 6 of the meaning of the words "integral horsepower" in which the Tribunal concluded that the preliminary determina tion of dumping did not apply to two digit frame size motors:
Evidence was adduced early in the proceedings concerning the significance of the words "integral horsepower" used in the Deputy Minister's preliminary determination. One inter pretation, based on the usual meaning of the word "integral", and supported by EEMAC, was that the preliminary deter mination applied to motors of one horsepower or more. If this interpretation is correct, inclusion of the words "integral horsepower" is unnecessary in view of the subsequent more precise specification, that the motors in question are "one horsepower (1 h.p.) to two hundred horsepower (200 h.p.) inclusive".
Accordingly, the Tribunal looked for an interpretation which, avoiding such redundancy, would represent a positive and relevant contribution to the definition of the class of goods in question. It did not have far to search, as there was ample evidence to demonstrate that the terms "integral" and "fractional" are in widespread use in the industry to distin guish between classes of induction motors on a basis other than their precise horsepower.
The technical standards of the industry in North America are established mainly by NEMA (National Electrical Manufacturers Association), an American association whose standards are, with few exceptions, adopted by EEMAC. NEMA has issued formal definitions for induction motors, which have been accepted by EEMAC and are reflected in the price lists and promotional literature of some EEMAC members, relating the terms "integral" and "fractional" to frame size identification. Under these definitions, "integral horsepower" motors have frames identified by three digit numbers while "fractional horsepower" motors have two digit frame numbers. Perhaps at one time, three digit frames were used only for motors of one horsepower and above, and two digit frames only for those below one horsepower; this would explain how the present usage developed. But if this was once the case, it is certainly not so today; in fact "fractional horsepower" motors (in two digit frames) may have ratings as high as five horsepower while there are "integral horsepower" motors (in three digit frames) having ratings less than one horsepower.
In light of the foregoing, the Tribunal is satisfied that the preliminary determination of dumping applies to induction motors having power ratings in the range of one to two hundred horsepower and constructed in three digit frames. It does not apply to motors with two digit frames ("fractional horsepower" motors), even if their power ratings are in the one to two hundred horsepower range, or to motors with three digit frames ("integral horsepower" motors) of power
ratings less than one horsepower. In addition, of course, there is the specific exclusion of "vertical-shaft pump motors gen erally referred to as vertical P-base or vertical P-flange motors".
It is the above decision of the Tribunal which the applicants seek to set aside.
It should first be observed that the complainants before the Tribunal were the Electrical and Elec tronic Manufacturers Association of Canada ("EEMAC") and six of its members in their individual capacities. The applicants in these pro ceedings were intervenants in the hearings before the Tribunal. They filed a memorandum of points of argument in which it was stated that:
At the present time however, the Applicants do not seek to disturb the findings of the Anti-dumping Tribunal and, indeed, the Applicants have sought to obtain the dismissal of this proceeding by filing Consents to the dismissal of it by the bulk of the parties who filed Notice of Intention to Participate. On the other hand, the Applicants do resist any attempt by any other party to modify the existing Order of the Anti-dumping Tribunal.
At the outset of the proceedings the applicants' counsel sought leave to withdraw from the pro ceedings without making any submissions, which leave was granted. Counsel for the Electrical and Electronic Manufacturers Association of Canada and for the Attorney General of Canada, appear ing on behalf of the Deputy Minister of National Revenue for Customs and Excise, both of whom refused to consent to the withdrawal of the section 28 application, argued in support of that applica tion. Counsel for the Tribunal opposed it. No question was raised or could have been raised as to the status of any of these parties to appear and their right to be heard.
Two issues were raised in the application. The Tribunal, in excluding induction motors having frames identified by two-digit numbers from the scope of its finding,
,(a) acted beyond its jurisdiction in purporting to define the class of goods to which the prelim inary determination of dumping applied, and
(b) erred in law in making its finding in the absence of any evidence to support such a finding.
The scheme of the Act has been reviewed by this Court on a number of occasions 2 so that it will not be necessary to do so again. Suffice it to say that the jurisprudence discloses that the formulation of the class of goods pursuant to subsection 13(1) of the Act, for the purpose of the preliminary deter mination, is the responsibility of the Deputy Min ister. When the Tribunal finds that certain dumped goods which are within the class defined by the Deputy Minister in his preliminary determi nation, are, in its view, "like goods" to certain goods produced in Canada, it has made a finding of fact which ought not to be disturbed by this Court unless there was no evidence upon which it could have been made or because a wrong princi ple was applied in making it. Under subsection 16(3), the Tribunal may make its order in respect of all or any of the "goods to which the prelim inary determination applies" and its decision as to whether there should be an exclusion or not is a question of fact or the exercise of a discretion, neither of which is a question of law falling within subsection 28(1)(b) of the Federal Court Act (see the Dryden House Sales Limited case, supra, pages 642-643).
In this case the Deputy Minister made a prelim inary determination of dumping in respect of the goods described as follows:
... integral horsepower induction motors, one horsepower (1 h.p.) to two hundred horsepower (200 h.p.) inclusive, exclud ing vertical-shaft pump motors generally referred to as vertical P-base or vertical P-flange motors, originating in or exported from the United States of America. [Emphasis added.]
The Tribunal found, pursuant to subsection 16(3) of the Act, that the dumping of the above- mentioned goods excluding certain additional motors "has caused, is causing, and is likely to cause material injury to the production in Canada of like goods". However, as will have been observed from the quotation from the "Statement
2 Magnasonic Canada Limited v. Anti-dumping Tribunal, [ 1972] F.C. 1239 (C.A.); Mitsui and Co. Limited et al. v. Buchanan, et al., [1972] F.C. 944 (C.A.); In re Anti-dumping Act and in re Y.K.K. Zipper Co. of Canada Ltd., [1975] F.C. 68 (C.A.); Remington Arms of Canada Limited v. Les Indus tries Valcartier Inc. et al., [1982] 1 F.C. 586 (C.A.); Sarco Canada Limited v. Anti-dumping Tribunal, et al., [1979] 1 F.C. 247 (C.A.); Dryden House Sales Limited, carrying on business under the firm name and style of Ambassador-Dry- den House v. Anti-dumping Tribunal, [1980] 1 F.C. 639 (C.A.).
of Reasons" of the Tribunal earlier set out herein, the Tribunal, not being certain of the meaning of the words "integral horsepower" as used in the Deputy Minister's preliminary determination, heard evidence, early in the proceedings in respect of the meaning to be ascribed to them. It is helpful to repeat its conclusion here:
In light of the foregoing, the Tribunal is satisfied that the preliminary determination of dumping applies to induction motors having power ratings in the range of one to two hundred horsepower and constructed in three digit frames. It does not apply to motors with two digit frames ("fractional horsepower" motors), even if their power ratings are in the one to two hundred horsepower range, or to motors with three digit frames ("integral horsepower" motors) of power ratings less than one horsepower. In addition, of course, there is the specific exclu sion of "vertical-shaft pump motors generally referred to as vertical P-base or vertical P-flange motors".
In the Trane case, supra, this Court held that it was permissible to refer to the reasons of the Tribunal to try to determine what the words "inte- gral horsepower" meant to the Tribunal. It was found that the reasons disclose that it did not intend to, and did not in fact, make a finding of material injury with respect to two-digit frame size motors. However, the Court also said this [at page 2061:
Whether the Tribunal had the authority to determine the scope of its inquiry by purporting to define the class of goods described in the preliminary determination of dumping is not in my opinion the issue in this appeal. The issue is whether, as a matter of fact, the Tribunal made a finding of material injury with respect to two digit frame size motors. If the Tribunal erred in excluding such motors from its inquiry and finding, the error might affect the validity of the Tribunal's decision ....
The issue left in abeyance in the Trane case is one of the issues before us in this application.
Counsel for EEMAC contended that the Tri bunal is not empowered to interpret words used in the preliminary determination of dumping. To do so would, he said, permit the Tribunal to redefine the class of goods encompassed by the determina tion either by abridging or enlarging it. This it is not entitled to do, in counsel's view, because of the words of subsection 16(1) reading:
16. (1) The Tribunal ... shall, in respect of the goods to which the preliminary determination of dumping applies, make inquiry ...
Certainly the words plainly limit the Tribunal's inquiry to the goods "to which the preliminary determination ... applies". However, in some cases, as here, the Tribunal may have difficulty in determining the goods to which the determination applies. If that is so it must endeavour to ascertain the meaning of the words. One of the ways in which that can be done is by permitting the adduc ing of evidence from those knowledgeable in the industry producing the goods at issue to ascertain, if possible, what the words mean to such persons. That is what the Tribunal did in the case at bar. To do so does not, in my view, necessarily result in a redefinition of the class of goods formulated by the Deputy Minister, as counsel argued. Embark ing on such a fact-finding mission at the hearing therefore, does not mean that the Tribunal is exceeding its jurisdiction as alleged by counsel.
Counsel for EEMAC, in his original presenta tion, argued that there is a legal obligation on the Tribunal to obtain from the Deputy Minister clari fication of the class of goods dumped if it is unsure what the class is. He agreed that there was no statutory obligation to do so but said that the obligation was implicit in the wording of Rule 9 of the Anti-dumping Tribunal Rules of Procedure, C.R.C., c. 300. 3 However, in reply, counsel conceded that there was no legal obligation to
3 9. The Deputy Minister shall, in accordance with para graph 14(2)(c) of the Act, submit to the Secretary for filing
(a) the complaint, if any, and all relevant information pro vided to him by the complainant;
(b) in the absence of a complainant, the evidence upon which the Deputy Minister relied to reach his opinion that the dumping of goods is causing injury to the production in Canada of like goods;
(c) a description of the goods dumped;
(d) information concerning the quantity and value of
(i) the production in Canada of like goods, and
(ii) the importation of like goods;
(e) information concerning the proportion of imports of the goods dumped or like goods that he discovers being dumped;
(f) the margins of dump; and
(g) any other available information in his possession relating to the inquiry.
adjourn the inquiry and to remit an unclear pre liminary determination to the Deputy Minister for clarification. To do so would be wise and prudent, he said, to ensure that the Tribunal did not exceed its jurisdiction by enlarging or abridging the scope of its inquiry. Counsel for the Attorney General, on the other hand, did not retreat from his conten tion that there was a legal obligation to remit but he could not point out the source of the obligation.
I am of the opinion that the Tribunal did not err or exceed its jurisdiction in endeavouring, in the circumstances of this case, to determine by evi dence what was meant by the words "integral horsepower induction motors". It had a duty to perform, which duty necessarily included the inter pretation of the class of goods formulated in the preliminary determination. How it achieved the interpretation was up to it to decide so long as it acted properly as a judicial or quasi-judicial body.
However, that does not end the matter. Counsel for the Attorney General of Canada, supported by counsel for EEMAC, took the position that if the Tribunal permitted evidence to be adduced to assist in determining the meaning to be ascribed to words in the determination and a question was raised as to its jurisdiction to do so, it must give its decision on that question before continuing the inquiry. In failing to decide the question before continuing, the parties were in the position of being unaware of the scope of the inquiry with respect to what goods evidence should directed and argument addressed. It was argued that failure to render its decision on the preliminary question before the hearing proceeded on the merits, con stituted an error in law and, in counsel's view, vitiated the whole proceedings.
A perusal of the evidence to which counsel referred us indicates clearly that the question of the meaning of the words "integral horsepower induction motors" was raised at a preliminary meeting of the parties with the Board as well as very early in the hearing before the Tribunal. An "initial ruling" as to what the words meant was requested at the meeting "because they affect
directly the evidence I would seek to adduce", one counsel said. It is equally clear that the Chairman of the Tribunal declined to make a ruling at the preliminary meeting, on the basis that evidence and argument would be required before an inter pretation could be given. It is interesting to note that it does not appear that either at that stage or at any later stage did any party suggest that clarification of the meaning of the words in the preliminary determination be sought from the Deputy Minister.
The position of the Tribunal was reiterated by the Chairman at the opening of the hearing and evidence was elicited from witnesses for the pur pose of ascertaining the meaning of the words. Furthermore, it is clear that the Tribunal did not, during the course of the hearing, disclose to the parties what it found to be their meaning. It was not until the Tribunal handed down its decision and gave its "Statement of Reasons" did it become known that the Tribunal had held that the prelim inary determination of dumping applied to induc tion motors having power ratings in the range of one to two hundred horsepower and constructed on three-digit frames and did not apply to motors with two-digit frames.
Counsel argued that the question thus is, did the failure of the Tribunal to make a decision on the meaning to be given to the term "integral horse power" in respect of induction motors, prior to proceeding with its inquiry, thereby depriving the parties of the opportunity to adduce evidence and address arguments to the specific goods under inquiry, (albeit those goods were part of a larger class of goods with respect to which evidence was adduced) constitute an error in law or of jurisdiction?
In my view, the question is not one of jurisdic tion in the usual sense in which that term is used. Neither do I view the error as one of law per se, but rather, as I see it, the Tribunal, by withholding its decision as to the scope of its inquiry, may have been in breach of a principle of natural justice.
Counsel for EEMAC referred us to a number of excerpts from the transcript of evidence at the preliminary meeting and at the inquiry hearings themselves. A perusal of those excerpts leaves no doubt in my mind that the Tribunal not only declined to make the ruling requested as to the meaning of the terms but did so because its mem bers were very uncertain at those times of the meaning which the term should be given. They wanted to hear evidence on the matter, not only that led by the complainants but also evidence from the opposing parties and time to consider that evidence before making a decision on the meaning. It seems to me, then, that any of the parties, having in mind what had transpired at the preliminary meeting and in the early stages of the hearing concerning the meaning to be attributed to the term "integral horsepower induction motors", might reasonably have expected that they would have been given an opportunity to lead evidence if the Tribunal decided that the narrower definition of the disputed term was the correct one. However, the Tribunal continued with the hearing without deciding what class of goods was the subject of the inquiry. Its failure to make the ruling as to the scope of the inquiry, may have deprived one or more of the parties of the opportunity not only to lead evidence specifically directed to the class of goods the Tribunal subsequently found to be the subject of the inquiry but to controvert, correct or comment on the evidence or information relevant to the finding the Tribunal is required to make by virtue of section 16 of the Act, namely, whether the importation of the three-digit motors had caused, was causing or would cause material injury to the production of like motors in Canada. The failure to afford the parties such an opportu nity, in my opinion, constituted a denial of natural justice.
For this reason, I am of the opinion that the section 28 application should be allowed, the deci sion of the Tribunal under review should be set aside and the matter should be returned to the Tribunal for a re-hearing in a manner not incon sistent with these reasons.
In view of this finding, it would not be proper for me to comment on the second issue raised, namely, that there was no evidence upon which the
Tribunal could have reached its decision with respect to the three-digit motors only.
RYAN J.: I agree.
KELLY D.J.: I concur in the reasons for judg ment herein of Urie J.
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