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Bias - Administrative Proceedings


MORE CASES

Part 2


. Landa v. The Dominion of Canada General Insurance Company

In Landa v. The Dominion of Canada General Insurance Company (Div Court, 2024) the Divisional Court cites the LAT's 'Code of Conduct', recusing member's from determining cases involving "any matter involving a firm where they worked immediately prior to that appointment":
[96] Ms. Landa alleged reasonable apprehension of bias. She did so on the basis that the LAT member who conducted two case conferences was previously affiliated with the law firm representing Dominion and on the basis that the LAT decisions were reconsidered by the same member who made the original decisions.

[97] There is a strong presumption that an administrative decision maker is impartial. The burden is on the party alleging bias and the grounds for making the allegation must be “substantial” (Wewaykum Indian Band v. Canada, 2003 SCC 45, [2003] 2 S.C.R. 259).

[98] According to LAT’s Code of Conduct, during the first two years of their appointment, members must not determine any matter involving a firm where they worked immediately prior to that appointment. The LAT member who conducted the case conferences in question was appointed to the LAT on January 24, 2018. The case conferences were conducted on April 6, 2020 and May 4, 2020 – more than two years after her appointment. Furthermore, she did not determine any substantive issues at the case conferences. In view of this, Ms. Landa has failed to meet her burden of establishing a reasonable apprehension of bias against the member who presided over the case conferences.
. Teksavvy Solutions Inc. v. Bell Canada

In Teksavvy Solutions Inc. v. Bell Canada (Fed CA, 2024) the Federal Court of Appeal dismisses a CRTC rate-setting appeal.

The court considers a bias issue, here where the appellant "says that the Chair of the CRTC met with a senior officer of the respondent, Bell Canada, while the matter leading to the decision in issue here was pending before the CRTC":
[54] Teksavvy raises another incident that it says gives rise to a reasonable apprehension of bias, one that on different facts and circumstances could indeed be problematic. Teksavvy says that the Chair of the CRTC met with a senior officer of the respondent, Bell Canada, while the matter leading to the decision in issue here was pending before the CRTC. For good measure, Teksavvy adds that the Chair attended ten other meetings with industry officials between November 2019 and the date of the decision under appeal. It is unclear whether the Chair attended alone or with other CRTC officials.

....

[64] Before closing on this issue, this Court has a general power of supervision over federal tribunals and it would be remiss if it did not offer a word or two about meetings between a regulator and a frequent party before it, such as the one in this case.

[65] Meetings between regulators and regulatees outside of the hearing room are a tricky area.

[66] At one end of the spectrum are meetings that are in the public interest, particularly where the regulator has a policy-making mandate and the regulator and the regulatee are in a long term relationship. Regulators need to understand the industry they regulate and the parties in it, their challenges, needs, aspirations, and plans. And regulatees need to understand the motivations of regulators, their view of the public interest and their need to protect it. It is evident from the register maintained under the Lobbying Act, most regulatees in sectors such as this engage in these meetings. It is accepted that they are part of doing business. For good measure, the preamble to the Lobbying Act has declared lobbying to be a "“legitimate activity”". And the CRTC’s Code of Conduct correctly recognizes that "“[f]ormal and informal contacts with parties with an interest in the communications industry are essential to maintaining and enhancing our expertise and knowledge”".

[67] At the other end of the spectrum are meetings to discuss live issues coming before the regulator or already before the regulator for hearing and decision. In effect, these meetings are means by which secret submissions can be offered outside of the hearing room, away from the eyes and ears of other parties to the hearing and the public. This subverts fairness and should not happen.

[68] Somewhere in the middle are social gatherings. The CRTC’s Code of Conduct permits attendance at social events and other meetings between CRTC members and industry representatives as long as CRTC members do not discuss matters before the CRTC during the events. But this can still invite unwelcome questions that can multiply, with mounting risk.

[69] Looking at this case as an example, why were the two together? What was discussed? Why were just the two of them there without any witnesses? Quite simply, meetings between two people, one a regulator and one a regulatee, without any independent witnesses or other evidence to substantiate why the meeting happened and what was discussed can be a recipe for trouble.

[70] In the evidentiary record before us is a CRTC policy that offers good practical guidance on this issue. It recognizes the benefits of regulator-regulatee meetings. But it also flags the risks and offers some ways the risks can be mitigated. For example, among other things, the policy suggests that a senior Commission staff person be present at such meetings. It also suggests that the purposes of the meeting be confirmed in writing.

[71] In the end, though, based on the paucity of evidence in this case, the informed, reasonable and right-minded person, viewing the matter realistically and practically and having thought the matter through, would not conclude that there was an actual or apprehended lack of impartiality on the part of the Chair: Committee for Justice and Liberty et al. v. National Energy Board et al., 1976 CanLII 2 (SCC), [1978] 1 S.C.R. 369, 68 D.L.R. (3d) 716; S. (R.D.) at para. 31.
. Equity Builders Ltd. et al. v. Landlord and Tenant Board et al.

In Equity Builders Ltd. et al. v. Landlord and Tenant Board et al. (Ont Divisional Ct, 2025) the Divisional Court (mostly) dismissed a multiple-proceeding combination of both LL-initiated JRs and RTA s.210 appeals, here respecting multiple units in a Sarnia apartment building. After a fire "the Chief Building Official for the City of Sarnia issued an order to the Landlord directing that the premises be vacated", followed by a second order several days later restricting access to a lesser number of units. The LL subsequently refused re-entry to tenants not covered by the later less restrictive order, eventually resulting in RTA orders of illegal lock-out for numerous units - and that "the Landlords had substantially interfered with the reasonable enjoyment by the Tenants of their units; and found that the Landlords obstructed, coerced, threatened or interfered with the Tenants".

Here the court considers (and rejects) the LL's argument that the LTB was biased against them:
Was the hearing procedurally unfair because the Board “descended into the fray” and was, therefore, biased against the landlord?

[119] The Landlords argue that the Board unfairly interjected during the testimony of the Landlords’ witnesses and interfered with their ability to answer questions. The Landlords also argue that the Board effectively became an advocate for the Tenants by conducting his own cross-examination of the landlord’s witnesses. In effect, the Landlords argue that there was a reasonable apprehension that the Board was biased against them and in favour of the tenants.

[120] We would not give effect to this ground of appeal. We are not satisfied that the Board did anything more than exercise its authority to control the process.

[121] There is a strong presumption that administrative decision makers are impartial: Yukon Francophone School Board, Education Area #23 v. Yukon (Attorney General), 2015 SCC 25, [2015] 2 S.C.R. 282, at para. 25; Halton (Regional Municipality) v. Canadian National Railway Company, 2024 ONCA 174, 171 O.R. (3d) 41, at para. 42. That presumption can only be displaced if the decision maker’s conduct, when assessed in context of the entire proceedings, gives rise to a reasonable apprehension of bias: R. v. S. (R.D.), 1997 CanLII 324 (SCC), [1997] 3 S.C.R. 484, at para. 114.

[122] Decision-makers are not expected to be passive during a hearing: Brouillard v. The Queen, 1985 CanLII 56 (SCC), [1985] 1 S.C.R. 39, at 44. At the same time, if a decision maker repeatedly interrupts the evidence, extensively cross-examining key witnesses or directly challenges a witness’ testimony during the hearing, that could give rise to a finding that the decision maker is no longer objective or impartial: Children’s Aid Society of the United Counties of Stormont, Dundas and Glengarry v S.V.D., 2016 ONSC 350, at para. 128. The assessment of whether a decision maker’s conduct creates a reasonable apprehension of bias must, therefore, be context-specific and fact-specific: Francophone School Board, at para. 26.

[123] Here, the landlord complains that the Board interfered with Mr. Singh’s ability to answer questions. On occasion, the Board did ask Mr. Singh to answer the questions he was asked. This was, however, after Mr. Singh repeatedly gave answers that were not responsive to the questions posed by the landlord’s counsel and offered his opinion on irrelevant issues. For example, at one point Mr. Singh was asked about how a specific tenant responded when the landlord asked them to remove their belongings. Rather than answering that question, Mr. Singh gave several answers about how that tenant wanted to be referred to by a different name than was on their government issued identification. The Board tried to redirect Mr. Singh to answer the question that the landlord’s lawyer had asked. A few minutes later, Mr. Singh was asked a question about the clause in the lease agreement used by Equity Builders about tenant insurance. Mr. Singh answered the question but then continued to give evidence about an issue that was not responsive to the question. The Board again reminded Mr. Singh to answer the questions he was asked. The Board said that was the final warning Mr. Singh would get and if he continued to give unresponsive, rambling answers, he would be fined. The Board then gave counsel for the landlord an opportunity to speak to Mr. Singh privately so counsel could explain the caution to Mr. Singh and give him instructions about how he to respond to question.

[124] We find that the Board’s interjections during Mr. Singh’s testimony were appropriate. The Board is required to ensure its hearings are expeditious and fair: Rules of Procedure, r. 1.4. To do so, the Board has the express authority to define and narrow the issues, question witnesses, and limit the evidence or submissions on any issue: Rules 1.6(m), 1.6(n) and 1.6(p). The Board’s interjections during Mr. Singh’s testimony were designed to ensure the hearing proceeded expeditiously and remained focussed on the issues the Board had to decide: El Sayed v. Ottawa Community Housing Corporation, 2019 ONSC 3703, at paras. 9-10, Chippewas of Mnjikaning First Nation v. Chiefs of Ontario, 2010 ONCA 47, 265 O.A.C. 247 at para. 243 and Cannon v. Cemcor Apartments Inc., 2017 ONCA 378, paras. 13-18. This was an extremely complicated matter in which the Board was considering 21 separate applications. The Board was required to control the process to ensure the hearing time was used effectively.

[125] There was nothing unfair about the Board’s cautions to Mr. Singh, particularly considering the Board’s decision to give Mr. Singh an opportunity to speak to counsel in private before continuing with his evidence. The fact that Mr. Singh made comments about feeling constrained in the way he answered questions after the Board’s two cautions does not render the cautions unfair. We are satisfied that Mr. Singh was able to fully answer the questions he was asked after the caution.

[126] The landlord also complains that the Board cross-examined its witnesses, including Ms. Rochon.

[127] The Board interjected during Ms. Rochon’s evidence and asked several questions. There is nothing inherently problematic about an administrative decision maker asking a witness questions. The Board’s Rules authorize the Boards to do so: Rules of Procedure, Rule 1.6(n). In this case, the Board apologized for the interruption and explained that it was trying to make sure it understood Ms. Rochon’s answers and that its notes were clear. The Board asked counsel for the landlord if counsel would prefer the Board to save all its questions for the end of Ms. Rochon’s evidence. Counsel for the landlord said he was “in the Board’s hands.” The Board then asked if either counsel had any concerns about his interventions “from a procedural fairness perspective.” Counsel for the landlord said that he was content with how things were proceeding. Counsel for the Tenants said they were used to Boards taking an active role in the hearings and did not feel the interventions were interfering with his ability to answer questions.

[128] If the landlord truly felt the Board’s interventions were creating an apprehension of bias or unfairness during the hearing, they were obliged to raise their concerns as soon as they arose: Techsavvy Solutions Inc. v. Bell Canada, 2024 FCA 121, at paras. 58-62. Here, counsel for the landlord did the opposite. When asked if the Board’s interventions were causing any unfairness, the landlord’s counsel did not raise any concerns and said they were “content” to carry on with the hearing. Having not raised the procedural fairness issues below, we are not prepared to give effect to these arguments on appeal.

[129] When the record of proceeding is considered as a whole, we are not satisfied the Board’s interventions during the evidence demonstrate a reasonable apprehension of bias.
. Ramsay v. Waterloo Region District School Board

In Ramsay v. Waterloo Region District School Board (Div Court, 2023) the Divisional Court considered a JR by a school board trustee against "the Waterloo Region District School Board (the “WRDSB”) ... which found that he had breached its Code of Conduct for Trustees (“Code of Conduct”) and imposed sanctions upon him as a result".

In these quotes, the JR applicant unsuccessfully challenges a school board disciplinary finding, here for bias:
[43] Ramsay further submits that the Chair’s involvement in the investigation process and his participation in casting votes tainted the decision with bias, or a reasonable apprehension of bias.

[44] Ramsay argues that by making submissions to the Integrity Commissioner the Chair was acting as both investigator and advocate which are roles that are incompatible with his ultimate role as a decision-maker. Ramsay argues that where a decision is made by multiple decision makers and one is disqualified on the basis of bias, the question becomes whether the entire panel is tainted. The Court must therefore evaluate the role of the decision-makers and whether the biased decision-maker had case the deciding vote (see: 101115379 Saskatchewan Ltd. v Saskatchewan (Financial and Consumer Affairs Authority), 2019 SKCA 31, [2019] 8 W.W.R. 67).

[45] In this case, the Chair was the deciding vote since a majority of two-thirds is required to confirm any finding that the Ramsay breached the Code of Conduct. But for the casting of the Chair’s vote, the finding could not have been confirmed and the decision would not have been made. Ramsay argues that the Chair’s role as author of the reasons and the necessity of his vote to the decision mean that his reasonable apprehension of bias taints the whole decision.

[46] The WRDSB points out that the Integrity Commissioner invited all of the trustees to make written submissions and that is why the Chair did so. The WRDSB submits that there was nothing wrong with the Chair’s providing of his submission to the Integrity Commissioner after having been invited to do so.

[47] The WRDSB argues that it cannot be said that the Chair’s submissions constituted bias that tainted the entire group of trustees when making the decision. It is evident from the Integrity Commissioner’s report that the Chair’s submissions were not shared with the other WRDSB trustees. The decision-maker in this case was the panel of the WRDSB as a whole, made up of nine voting trustees. There is no evidence that five other trustees who comprised the majority were biased or tainted by the alleged apprehension of bias of the Chair, nor does the Chair’s submission in response to the invitation from the Integrity Commissioner raise any reasonable apprehension that they were biased (see: R. v. Roberts, 2005 SCC 3, [2005] 1 S.C.R. 22).

[48] I agree with the approach taken by the WRDSB to this issue in its argument. Ramsay’s concerns of bias must be evaluated against the particular structure of the board of trustees and its processes for the handling of complaints against any individual trustee. Indeed, it is only a trustee who is able to bring a formal complaint against another trustees. The Code of Conduct prohibits the trustee who filed the complaint from voting on the disciplinary resolution, but does not otherwise prohibit other trustees from being witnesses, providing such information as they may have to the Integrity Commissioner, and participating in the decision-making process. The very nature of many of the requirements of expected conduct of trustees as contained in the Code of Conduct makes it likely that other trustees may often be ‘witnesses” to such conduct. This does not raise any spectre of bias in such a setting.

[49] Accordingly, given the nature of the complaint, the observation that the basic facts underlying it were not disputed, and the context of the decision itself, I conclude that there is no basis for a finding of bias here nor any denial of procedural fairness to Ramsay.
. A. Z. v. Office of the Independent Police Review Director

In A. Z. v. Office of the Independent Police Review Director (Div Court, 2023) the Divisional Court considered a JR of the dismissal of OIPRD screening, investigation and examination of a complaint of local police misconduct, here regarding their handling of sexual assault allegations. Paras 1-35 are illustrative of police and OIPRD procedures in such matters.

In these quotes the court considers bias, here in an statutory and administrative OIPRD (police complaint) context:
[55] A reasonable apprehension of bias is to be determined not from the standpoint of the decision-making organisation, or from that of the complainant. Rather, the person considering the alleged bias must be reasonable, and the apprehension of bias itself must also be reasonable in the circumstances of the case: R. v. S. (R.D.), 1997 CanLII 324 (SCC), [1997] 3 S.C.R. 484, at para. 111.

[56] It is not an answer to an allegation of reasonable apprehension of bias to say that there is no evidence that actual bias was displayed by the NRPS investigation into the applicant’s complaints. It is sufficient that if a reasonable and informed person would have reasonable concerns about the ability of the NRPS to conduct an impartial and unbiased investigation into five of its own, a reasonable apprehension of bias would be established.

[57] While public expectations in relation to the police complaints system in Ontario have evolved over the last two decades, it remains open to a police service to investigate a complaint into its own officers.

[58] In his Report on the Police Complaints System in Ontario (Toronto: Ministry of the Attorney General of Ontario, 2005), the Honourable Patrick J. LeSage, Q.C., expressly rejected the proposition that police services could not investigate themselves.

[59] By contrast, the Honourable Michael H. Tulloch (now Chief Justice of Ontario), in his 2017 Report of the Independent Police Oversight Review (Toronto: Queen’s Printer for Ontario, 2017) (“Tulloch Report”), noted, at p. 167:
Many of the people with whom I spoke expressed a strong desire to have an independent, civilian body investigating police misconduct, rather than police services themselves. Irrespective of issues of actual bias, they noted the potential for a perception of bias when police officers investigate other police officers in their same force.
Such views led Tulloch J.A. (as he then was) to recommend that within five years, the OIPRD should be the sole body to investigate police misconduct complaints.

[60] However, this recommendation from the Tulloch Report was not adopted by the government when it enacted the Community Safety and Policing Act, 2019, S.O. 2019, c. 1., Sched. 1. To the contrary, the new legislation, once proclaimed, would create a presumption in favour of having the same police service conduct investigations.

[61] Further, currently, s. 61(5) of the PSA explicitly permits the investigation of a complaint to be referred to the same police service for investigation. The statutory scheme does not require that complaints be sent to a different service, or that they be retained by the OIPRD. In exercising the discretion to retain the complaint or to refer it to the same or different police service, s. 61(6) of the PSA requires the Director to consider the nature of the complaint and the public interest. Further, Rule 7 of the OIPRD’s Rules of Procedure sets out a list of non-exhaustive factors to be considered in making the decision to refer or retain the investigation of a complaint. The OIPRD’s Operational Directive provides further guidance in making this determination.

[62] The applicant relies on the portion of the Operational Directive that provides, as an example of a complaint the Director may retain or refer, “[a]llegations of substandard police investigation of sexual assaults…where effective oversight cannot be achieved by referring the complaint to a different police service other than the one that undertook the original investigation.” However, the Operational Directive provides guidance, not mandatory instruction. It also states that the decision to retain or refer is made on a case-by-case basis. It does not contain a presumption that allegations of substandard police investigation of sexual assaults be retained by the OIPRD or be referred to a different police service than the one that undertook the original investigation.

[63] In the present case, the record clearly demonstrates that at the screening stage, the OIPRD was alert to the question of whether or not investigation of the applicant’s complaints should be undertaken by the NRPS, or by an external force, or by the OIPRD itself. This is evidenced by the fact that one of the four OIPRD personnel involved at the screening stage did support referring the matter out to another police service. The other personnel, however, found that the factors that would support a referral to a different police service were not engaged. It is evident from the record that due consideration was given to the issue.

[64] Contrary to the applicant’s belief, the investigation was not conducted by the same unit as the one to which the complaint pertained. The complaint was investigated by the Professional Standards Unit, as opposed to the Sexual Assault Unit. In the end, two officers were found to have violated certain policies relating to sexual assault investigations and were found to be in neglect of duty.

[65] In addition, the NRPS has a review body, the Sexual Violence Advocate Case Review Team, which examines all sexual assault allegations where charges are not laid. This review body is composed of civilians who represent various advocacy groups in the Niagara region. None of the members of the review body are employees of the NRPS. The review body can make recommendations to the Sexual Assault Unit if its members have a concern about an investigation. The review body did not make any recommendations in this case.

[66] Overall, the OIPRD reviewed the specific circumstances of this case and exercised its discretion to refer the complaint to a different unit of the same police service, where there would also be oversight by a civilian review body. A reasonable person would not find these circumstances raised a reasonable apprehension of bias.

[67] Based on the foregoing, we are not satisfied that there was actual or a reasonable apprehension of bias.
. Sternberg v Ontario Racing Commission

In Sternberg v Ontario Racing Commission (Div Ct, 2008), the applicant lawyer sought to quash a decision that he be barred from appearing before the Commission until he apologized for alleged misconduct. The court application was grounded in bias as the Commission panel making the misconduct finding included two of the original members whom he is alleged to have offended, and because the reasons in the contempt decision were prepared before the hearing was conducted (and as well mistated the fact that he had not apologized).

The application was allowed for these reasons, and additionally because the 'misconduct' hearing was essentially a contempt hearing, which jurisdiction resides with the Divisional Court [SPPA s.13(1)(c)] and - at least with respect to professional discipline, the Law Society - not the Commission. As well, the applicant was denied the oppourtunity to make submissions as to penalty.

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

In Nathalie Xian Yi Yan v. College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario (Div Court, 2022) the Divisional Court set out the standard for an administrative decision-maker's bias:
[66] It is a fundamental principle of law that any decision-maker must be impartial and unbiased. There is a presumption that tribunals such as the Discipline Committee of the College will act without bias. In Ritchot v The Law Society of Manitoba, 2010 MBCA 13 at paras 37–38, the Manitoba Court of Appeal wrote:
Judges are presumed to be impartial and “[t]he burden of proof is on the party alleging a real or apprehended breach of the duty of impartiality … [to] establish actual bias or a reasonable apprehension of bias” …

A similar presumption of impartiality applies to an administrative tribunal. See Zündel v. Toronto Mayor’s Committee on Community and Race Relations (2000), 2000 CanLII 17137 (FCA), 189 D.L.R. (4th) 131 (Fed. C.A.), application for leave to appeal dismissed, [2000] S.C.C.A No. 322 (QL), in which Sexton J.A. wrote of the “principle that a member of a Tribunal will act fairly and impartially, in the absence of evidence to the contrary” (at para 36). More recently, in Imperial Oil Ltd. v. Quebec (Minister of the Environment), 2003 SCC 58 (CanLII), [2003] 2 S.C.R. 624, LeBel J. wrote that “[t]he duty of impartiality, which originated with the judiciary, has now become part of the principles of administrative justice” (at para. 28).
. Corporation of County of Simcoe v. Ontario

In Corporation of County of Simcoe v. Ontario (Div Court, 2022) the Divisional Court characterized what constitutes bias in this judicial review administrative context, here though the bias was alleged against an inspector who testified as to the facts alleged:
Reasonable Apprehension of Bias

[34] Administrative decisions must be made by an impartial decision maker, free from a reasonable apprehension of bias. Actual bias need not be demonstrated, nor must a party prove that the apprehended bias prejudiced or changed the outcome of the case. The test is an objective one. As noted by DeGrandpré J. in Committee for Justice and Liberty v. National Energy Board:
... the apprehension of bias must be a reasonable one, held by reasonable and right-minded persons, applying themselves to the question and obtaining thereon the required information... [T]hat test is "what would an informed person, viewing the matter realistically and practically - and having thought the matter through - conclude. Would he think that it is more likely than not that [the decision-maker], whether consciously or unconsciously, would not decide fairly."

The grounds for this apprehension must, however, be substantial and I ... refus[e] to accept the suggestion that the test be related to the "very sensitive or scrupulous conscience".
The stringency of the test for bias varies with the circumstances, including the context of the decision maker’s activities and the nature of its functions. [9]
. Briarlane v. Limas

In Briarlane v. Limas (Div Ct, 2020) the Divisional Court quotes a standard for bias in an administrative context:
[29] As noted in Roberts v. R., 2003 SCC 45, there is a strong presumption of judicial and quasi-judicial impartiality. In order to overcome that presumption, the burden is on the party alleging bias to provide strong cogent evidence in that regard. The Tenants have provided no such evidence in this case. There is no transcript of the earlier hearing before us. The Tenants’ description of the comments made, however, amount to nothing more than the Member controlling the process. Further, a review of the transcript of the proceedings before the Board on May 6, 2019, raises no indication whatsoever of any bias by the Board towards the Tenants.
. The Association of Professional Engineers of Ontario v. Rew

In The Association of Professional Engineers of Ontario v. Rew (Div Ct, 2020) the Divisional Court stated the bias test applicable to administrative matters:
[55] The test for reasonable apprehension of bias in the administrative law context is whether a reasonably informed bystander could reasonably perceive bias on the part of the adjudicator: Newfoundland Telephone Co. v. Newfoundland (Board of Commissioners of Public Utilities), 1992 CanLII 84 (SCC), [1992] 1 S.C.R. 623 at 636.


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Last modified: 13-02-25
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