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ADMINISTRATIVE LAW | SPPA / Fairness (Administrative)

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Administrative - Corrections to Orders [SPPA 21.1]

. Yan v. College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario

In Yan v. College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario (Div Court, 2022) the Divisional Court briefly reviewed a straighforward application of SPPA s.21.1 [here, also apparently replicated in HRTO Rules 25.1]:
Was it procedurally unfair or unreasonable for the HRTO to make minor corrections to its initial decision?

[17] The Tribunal’s corrections to its reasons also does not provide a basis to interfere with its decision.

[18] Rule 25.1 of the Rules of Procedure of the HRTO provides that, within 30 days from the date of a decision or order, a party may request that the Tribunal correct a typographical error, error of calculation, or similar error made in the decision or order.

[19] Here, following the release of the initial decision, College counsel wrote to the Tribunal, copying Ms. Yan, to request minor amendments to the decision. Specifically, the original decision incorrectly stated that the committee of the College that heard the discipline matter was the Inquiries, Complaints and Reports Committee (“ICRC”), when in fact it was the Discipline Committee. This was apparent from the face of the Discipline Committee's decisions, which had been filed as part of the College's written submissions on the preliminary hearing. The Tribunal issued a revised decision, mostly correctly naming the Discipline Committee in its revised reasons. However, College counsel then wrote to advise there were still three incorrect references to the ICRC in the decision, which the Tribunal subsequently corrected.

[20] The correction process was procedurally fair and transparent. Ms. Yan was copied on the College's requests and the HRTO's responses. Ms. Yan raised no objection at the time. The corrections were minor errors and in the nature of typographical errors. I do not find any basis to interfere in the Tribunal’s correction of the decision.


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Last modified: 14-05-23
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