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Statutory Interpretation - "In Connection With". Purolator Inc. v. Canadian Union of Postal Workers
In Purolator Inc. v. Canadian Union of Postal Workers (Ont CA, 2026) the Ontario Court of Appeal allowed a union's appeal, this brought against "injunctions obtained by Purolator Inc. ... restraining picketing at Purolator’s Ontario premises by members of the Canadian Union of Postal Workers (“CUPW”), who were at the time on strike against their employer, Canada Post Corporation (“Canada Post”)."
Here the court considers the meaning of the phrase "in connection with" from a statutory interpretation perspective:[36] I note that the words “in connection with” have been interpreted by this court in a number of different contexts and have repeatedly been found to have a very broad meaning: see e.g., Mantini v. Smith Lyons LLP (2003), 2003 CanLII 20875 (ON CA), 64 O.R. (3d) 505 (C.A.), at para. 19, leave to appeal refused, [2003] S.C.C.A. No. 344; Lawrence v. Toronto Humane Society (2006), 2006 CanLII 20224 (ON CA), 212 O.A.C. 263 (C.A.), at paras. 83-85; see also Intercap Equity Inc. v. Bellman, 2022 ONCA 61, 160 O.R. (3d) 536. The term “connection” means “there is some relationship between two things or activities – that they have something to do with each other”: Lawrence, at para. 85, citing Re Kitchener-Waterloo Real Estate Board Inc. and Ontario Regional Assessment Commissioner, Region No. 21 et al (1986), 1986 CanLII 2660 (ON HCJ), 56 O.R. (2d) 94 (H.C.), at p. 103. This jurisprudence suggests that a broad and inclusive interpretation should be given to the phrase “in connection with a labour dispute” in s. 102 of the CJA. . The Governing Council of the Salvation Army in Canada v. Patient Ombudsman
In The Governing Council of the Salvation Army in Canada v. Patient Ombudsman (Ont CA, 2023) the Court of Appeal considers the statutory interpretation to be applied to the phrase "in connection with":[4] We also do not agree that the appellant’s investigation was not in connection with a matter that was the subject of these other proceedings. The language used in s. 13.3(5), namely, “in connection with” is very broad – see Nowegijick v. The Queen, 1983 CanLII 18 (SCC), [1983] 1 S.C.R. 29 at p. 39. The appellant’s attempt to compartmentalize the subject matter of these other proceedings so as to separate them from the subject matter of its investigation fails to recognize the breadth of that language. The overlap between at least some of these proceedings is evident. . Intercap Equity Inc. v. Bellman
In Intercap Equity Inc. v. Bellman (Ont CA, 2021) the Court of Appeal considered the statutory interpretation of the phrase "in connection with":[58] This Court has repeatedly held that the phrase “in connection with” has a very broad meaning: Mantini v. Smith Lyons LLP (2003), 2003 CanLII 20875 (ON CA), 64 O.R. (3d) 505 (C.A.), at para. 19, leave to appeal refused, [2003] S.C.C.A. No. 344; Lawrence v. Toronto Humane Society (2006), 2006 CanLII 20224 (ON CA), 271 D.L.R. (4th) 329 (Ont. C.A.), at para. 84. The term “connection” means “there is some relationship between two things or activities – that they have something to do with each other”: Lawrence, at para. 85, citing Kitchener-Waterloo Real Estate Board Inc. v. Ontario Regional Assessment Commissioner, Region No. 21 (1986), 1986 CanLII 2660 (ON SC), 56 O.R. (2d) 94 (H.C.).
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