Consultation with First Nations and Accommodation Obligations
|
|
- Shawn Bond
- 1 years ago
- Views:
Transcription
1 Consultation with First Nations and Accommodation Obligations John J.L. Hunter, Q.C. prepared for a conference on the Impact of the Haida and Taku River Decisions presented by the Pacific Business and Law Institute, January 26-27, 2005, Vancouver, B.C. On November 18, 2004, the Supreme Court of Canada released its long-awaited decision in Council of the Haida Nation v. British Columbia 1 and the related case of Taku River Tlingit First Nation v. Minister of Forests 2. This unanimous decision provides much-needed clarification of the duties of consultation and accommodation in respect of government decisions which may impact on aboriginal rights. This paper will provide an overview of the main elements of the Court s decision. I Summary of the Court s Decision 1. There were three issues before the Court: (i) whether the Crown has an obligation to consult Aboriginal people claiming unproven rights before making a decision that may infringe on those rights if proven; SCC 73 [ Haida (SCC) ] SCC 74
2 2 (ii) (iii) if so, whether the obligation includes an obligation to accommodate these asserted interests; and whether third parties obtaining rights through the Crown have a similar obligation to consult and/or accommodate Aboriginal interests. 2. The Court concluded that the Crown does have an obligation to consult prior to the establishment of the asserted rights. Third parties, however, do not. 3. The Court also concluded that the obligation to consult may carry with it an obligation to accommodate, or may not. That depends on what is discovered through the consultation process. 4. Where accommodation is required, the Aboriginal interest must balanced with other interests. The Aboriginal claimants do not have a veto over government action. II. Source of the Duty to Consult 5. One of the perplexing questions in this area of the law has been what the source of a Crown obligation to consult might be. The two sources suggested in the Courts below have been the Crown s fiduciary relationship with Aboriginal people and the Delgamuukw decision. The Supreme Court rejected both of these as potential sources. Instead, the Court held that the source for this obligation was the honour of the Crown. (i) Fiduciary principles do not apply. 6. The B.C. Court of Appeal had held that the source of this duty was the fiduciary relationship between the Crown and Aboriginal people. Writing for a unanimous panel in Haida I, Lambert J.A. expressed the principle in this way 3 : 3 Haida Nation v. British Columbia and Weyerhaeuser (2002), 99 B.C.L.R. (3d) 209, 2002 BCCA 147, paras [ Haida I (BCCA) ]
3 3 In my opinion, the roots of the obligation to consult lie in the trust-like relationship which exists between the Crown and the aboriginal people of Canada.... The trust-like relationship is now usually expressed as a fiduciary duty owed by both the federal and Provincial Crown to the aboriginal people. Whenever that fiduciary duty arises, and to the extent of its operation, it is a duty of utmost good faith.... So the trust-like relationship and its concomitant fiduciary duty permeates the whole relationship between the Crown, in both of its sovereignties, federal and provincial, on the one hand, and the aboriginal peoples on the other. One manifestation of the fiduciary duty of the Crown to the aboriginal peoples is that it grounds a general guiding principle for s. 35(1) of the Constitution Act, Even before the Supreme Court s decision in Haida, this view of the Crown fiduciary relationship with aboriginal people had been undermined. In Wewaykum Indian Band v. Canada 4, after referring to some of the leading decisions on fiduciary obligations and relating them to the established categories in relation to aboriginal people, Binnie J., speaking for a unanimous court, said this: But there are limits. The appellants seemed at times to invoke the "fiduciary duty" as a source of plenary Crown liability covering all aspects of the Crown- Indian band relationship. This overshoots the mark. The fiduciary duty imposed on the Crown does not exist at large but in relation to specific Indian interests. 8. Binnie J. then points out without specific comment what he describes as a flood of fiduciary duty claims by Indian bands across a whole spectrum of possible complaints and makes the following comments about fiduciary obligations: I think it desirable for the Court to affirm the principle, already mentioned, that not all obligations existing between the parties to a fiduciary relationship are themselves fiduciary in nature (Lac Minerals, supra, at p. 597), and that this principle applies to the relationship between the Crown and aboriginal peoples. It is necessary, then, to focus on the particular obligation or interest that is the subject matter of the particular dispute and whether or not the Crown had assumed discretionary control in relation thereto sufficient to ground a fiduciary obligation SCC 79, at para (emphasis added) 5 ibid, at para. 83
4 4 9. In the Supreme Court s decision in Haida 6, the Court specifically rejected the fiduciary characterization as a source for the obligation of the Crown to consult in these terms: As explained in Wewaykum, at para. 81, the term "fiduciary duty" does not connote a universal trust relationship encompassing all aspects of the relationship between the Crown and Aboriginal peoples:... "fiduciary duty" as a source of plenary Crown liability covering all aspects of the Crown-Indian band relationship.... overshoots the mark. The fiduciary duty imposed on the Crown does not exist at large but in relation to specific Indian interests. Here, Aboriginal rights and title have been asserted but have not been defined or proven. The Aboriginal interest in question is insufficiently specific for the honour of the Crown to mandate that the Crown act in the Aboriginal group's best interest, as a fiduciary, in exercising discretionary control over the subject of the right or title. 10. Later in the judgment, in rejecting the argument that third party licensees might owe a fiduciary duty to aboriginal people, the Court said pointedly, that the duty to consult is distinct from the fiduciary duty that is owed in relation to particular cognizable Aboriginal interests. 7 (ii) Delgamuukw is relevant but not controlling. 11. In the Court of Appeal, Lambert J.A. cited Delgamuukw extensively, but appeared to distinguish the pre-proof consultation from consultation in the infringement/justification analysis expressed in the Sparrow decision 8 : The duty to consult and seek an accommodation does not arise simply from a Sparrow analysis of s. 35. It stands on the broader fiduciary footing of the Crown's relationship with the Indian peoples who are under its protection. 12. The Supreme Court reviews the Sparrow/Delgamukw line of infringement/justification cases in its explanation of the sources of the duty to consult 9, and quoted the principal paragraph 6 Haida (SCC), para Haida (SCC), para Haida I (BCCA), para Haida (SCC), para
5 5 from Delgamuukw dealing with the nature and scope of consultation in a justification analysis, 10 indicating that the Delgamuukw concepts of consultation have some application to pre-proof situations. However, the Court also distinguishes the two types of consultation, particularly in its rejection of any aboriginal veto: The Aboriginal consent spoken of in Delgamuukw is appropriate only in cases of established rights, and then by no means in every case It appears that rather than regarding the Delgamuukw principle as a source for the preproof consultation, the Court regards the need for consultation in an infringement context as arising from the same general source of the Government s sui generis obligations to Aboriginal people, namely the honour of the Crown. (iii) The source of the duty to consult is the honour of the Crown. 14. The Supreme Court is quite clear that the source of the duty to consult is the honour of the Crown. This judgment represents the first time that the honour of the Crown has been relied upon as the source of a positive duty to act. Previously the Court had referenced the honour of the Crown primarily in relation to treaty interpretation and application The Court explains that it is the honour of the Crown that underlies all dealings of the Government with Aboriginal people: The government's duty to consult with Aboriginal peoples and accommodate their interests is grounded in the honour of the Crown. The honour of the Crown is always at stake in its dealings with Aboriginal peoples: see for example R. v. Badger, [1996] 1 S.C.R. 771, at para. 41; R. v. Marshall, [1999] 3 S.C.R It is not a mere incantation, but rather a core precept that finds its application in concrete practices. The historical roots of the principle of the honour of the Crown suggest that it must be understood generously in order to reflect the underlying realities from which it stems. In all its dealings with Aboriginal peoples, from the assertion of sovereignty 10 Haida (SCC), para Haida (SCC), para See e.g. R. v. Badger, [1996] 1 S.C.R. 771 and R. v. Marshall, [1999] 3 S.C.R. 456, referenced by the Court at para. 16
6 6 to the resolution of claims and the implementation of treaties, the Crown must act honourably. Nothing less is required if we are to achieve "the reconciliation of the pre-existence of aboriginal societies with the sovereignty of the Crown": Delgamuukw, supra, at para. 186, quoting Van der Peet, supra, at para It is the honour of the Crown that is the source of the fiduciary duty that arises when (and only when) the Crown has assumed discretionary control over specific aboriginal interests. 17. There is no real analysis of the scope of the honour of the Crown in the judgment, but it is clear that the Court will not countenance Government acting towards Aboriginal people in a way that the Court regards as dishonourable. The development of principles of equity provides an obvious analogue for this concept, but the Court s increasingly narrow view of the scope of the Government s fiduciary obligations towards Aboriginal people suggests that equitable principles are unlikely to provide a reliable guide to understand the scope of enforceable duties which may be attributable to its obligation not to act dishonourably. 18. Since Haida and Taku River were released, the Federal Court of Appeal has released a judgment summarizing the scope of the honour of the Crown principle, concluding with this statement of principle 14 : I conclude that, with respect to the honour of the Crown, the concrete practices required of the Crown so far identified by the Supreme Court of Canada in the Aboriginal context are: acting appropriately as a fiduciary; interpreting treaties and documents generously; negotiating, and where appropriate, consulting with and accommodating Aboriginal interests; and justifying legislative objectives when Aboriginal rights are infringed. However, I do not suggest that this is an exhaustive list of the ways in which the honour of the Crown may be manifest. 19. However the Court rejected an extension of the principle to the conduct of ordinary litigation by the Crown 15. III. Circumstances requiring Consultation 13 Haida (SCC), para Stoney Band v Canada, 2005 FCA 15, at para ibid., para 21-33
7 7 20. The threshold here is a low one. The Crown must consult whenever the Government has knowledge, real or constructive, of the potential existence of an aboriginal right or title and contemplates conduct that might adversely affect it This is a concept similar to that proposed by the Court of Appeal. The difference in approach seems to be this: the Court of Appeal appears to set a slightly higher standard for when consultation is necessary, but then impose a greater substantive obligation to seek an accommodation of Aboriginal concerns. The Supreme Court on the other hand requires consultation in virtually any case where it might be necessary, but does not necessarily require any substantive element. 22. The Supreme Court does acknowledge the difficulty in addressing rights that have been asserted but not yet proven, and puts some onus on the Aboriginal claimant to clearly outline their claims: It is said that before claims are resolved, the Crown cannot know that the rights exist, and hence can have no duty to consult or accommodate. This difficulty should not be denied or minimized. As I stated (dissenting) in Marshall, supra, at para. 112, one cannot "meaningfully discuss accommodation or justification of a right unless one has some idea of the core of that right and its modern scope". However, it will frequently be possible to reach an idea of the asserted rights and of their strength sufficient to trigger an obligation to consult and accommodate, short of final judicial determination or settlement. To facilitate this determination, claimants should outline their claims with clarity, focussing on the scope and nature of the Aboriginal rights they assert and on the alleged infringements. 17 IV. Requirements of Consultation 16 Haida (SCC), para Haida (SCC), para. 36. For an earlier expression of this obligation, see Husby Forest Products v. British Columbia, 2004 BCSC 142 at paras. 94 and 96: It was incumbent on the Haida, if they did object to the granting of the cutting permits, to clearly define the nature and scope of the aboriginal right they claimed was being infringed. The Haida must delineate whether they claim the right to red cedar and specifically what that means in relation to these cutting permit application, or the right to harvest cedar, or the right to preserve CMTs, or the right to preserve what they call the archaeological forests or some other right not yet encompassed in the various claims mentioned. They must do so in a site specific way.
8 8 23. The Supreme Court offers no bright line test for consultation, but instead uses the by now familiar spectrum approach to determining what must be done. 24. The content of the duty to consult and accommodate varies with the circumstances. The scope of the duty will be proportionate to a preliminary assessment of the strength of the case supporting the existence of the right or title, and to the seriousness of the potentially adverse effect upon the right or title claimed. If the claim is weak or the potential for infringement minor, the only duty on the Crown may be to give notice, disclose information, and discuss any issues raised in response to the notice. If the claim is strong, the potential infringement significant and the risk of non-compensable damage high, deep consultation, aimed at finding a satisfactory interim solution, may be required. The approach is to be one of balance and compromise on all sides. 25. The Court does state that there is no duty to agree, a theme the Court returns to in its discussion of accommodation. The Court also adopts a proposition developed in the British Columbia courts that Aboriginal claimants must not frustrate the Crown s reasonable good faith attempts, nor should they take unreasonable positions to thwart government from making decisions in cases where, despite meaningful consultation, agreement is not reached. 18 V. The Accommodation Requirement 26. One of the significant changes in approach coming out of Haida is the treatment of accommodation, which been de-linked from consultation. Consultation is required at any time when government-approved action may interfere with claimed aboriginal rights, but whether the Government needs to accommodate aboriginal concerns will depends on the result of the consultation process. If the consultation process indicates the need to take steps to avoid irreparable harm or to minimize the effects of infringement, a duty to do so may arise. 27. The Court explained the requirement in this passage: 18 Haida (SCC), para. 36
9 9 When the consultation process suggests amendment of Crown policy, we arrive at the stage of accommodation. Thus the effect of good faith consultation may be to reveal a duty to accommodate. Where a strong prima facie case exists for the claim, and the consequences of the government's proposed decision may adversely affect it in a significant way, addressing the Aboriginal concerns may require taking steps to avoid irreparable harm or to minimize the effects of infringement, pending final resolution of the underlying claim The Court spends some time on the definition of accommodation. It is clear that accommodation does not mean meeting the concerns raised, but rather altering the decision to balance the aboriginal concerns with other non-aboriginal interests. Accommodation refers to reconciling and compromising interests. 29. Accommodation does not mean the aboriginal group has a veto. This is made very clear in the following passage: This process does not give Aboriginal groups a veto over what can be done with land pending final proof of the claim. The Aboriginal consent spoken of in Delgamuukw is appropriate only in cases of established rights, and then by no means in every case. Rather, what is required is a process of balancing interests, of give and take In British Columbia, a practice has developed of equating accommodation with some form of compensation for Aboriginal claimants prior to establishing their claims. The term accommodation package has been developed to refer to the basket of incentives offered to Aboriginal claimants who challenge government-approved projects on land they claim. This practice seems very much at odds with the concept of accommodation as explained by the Supreme Court. 31. The Court clearly relates accommodation to a modification of the Government s plans in order to harmonize those plans with Aboriginal interests or concerns whenever reasonably possible. Some care is spent on this part of the judgment, even to the point of looking at dictionary definitions of accommodate. The result is an emphasis on harmonization rather than compensation: 19 Haida (SCC), para Haida (SCC), para. 48
10 10 The accommodation that may result from pre-proof consultation is just this -- seeking compromise in an attempt to harmonize conflicting interests and move further down the path of reconciliation. A commitment to the process does not require a duty to agree. But it does require good faith efforts to understand each other's concerns and move to address them. 21 VI. Obligations of the Private Sector 32. The B.C. Court of Appeal had held that the obligation to consult and accommodate aboriginal interests extended to third licensees operating on Crown land, either generally as an independent obligation (per Lambert J.A.) or at least on some occasions when it was necessary in order to provide an effective remedy against the Crown (per Finch, C.J.B.C.). 33. The Supreme Court of Canada decisively rejected this proposition. Industry does not have an obligation to consult or accommodate aboriginal interests: The Crown alone remains legally responsible for the consequences of its actions and interactions with third parties that affect Aboriginal interests The Court pointed out that it was open to the Government to delegate procedural aspects of consultation to industry proponents seeking a particular development, and references the terms of Weyerhaeuser s licence approvingly. It is clear, however, that this is a matter between the Crown and the licensees. It does not give rise to an obligation enforceable by Aboriginal people against licensees, who cannot be held liable for failing to discharge the Crown s duty to consult and accommodate Haida (SCC), para Haida (SCC), para Haida (SCC), para. 56
11 As a practical matter of course, industry has a considerable interest in ensuring that the Government conducts the consultation properly. The reality is that while Courts have been reluctant to set aside permits granted to third parties because of the Government s failure to consult properly, that is always a possible outcome, and the impact of such a remedy would fall on the permit holder. VII. Regulatory Proposals 36. The Court seems to be encouraging Governments to establish administrative processes to guide decision-makers in the consultation process. If this is done, and the consultation is carried out fairly and properly, the Court has indicated that judicial review of the Government s conclusion would be carried out on a reasonableness standard. In other words, the Government s conclusions as to the accommodation required would be upset by the Court only if the Court concluded that they were unreasonable. Such a standard of review affords considerable deference to the decision-maker, and may prove to be a strong incentive for Governments to make their consultation procedures more systematic. 37. With this judgment in hand, it does seem appropriate for governments to review those statutes and administrative regimes that could lead to infringement of aboriginal rights with a view to providing better guidance for statutory decision-makers. The judgment raises the spectre of the Adams decision to encourage governments to begin this review. The risk is that statutory schemes may be vulnerable to attack if they amount to an unstructured discretionary administrative regime which risks infringing aboriginal rights R. v. Adams, [1996] 3 S.C.R. 101, at para. 54, cited at Haida (SCC), para. 51
12 The Court seems to view the Province s Consultation Guidelines 25 as a step in the right direction, although there seems to be a preference for a more traditional regulatory regime. 39. No direction was made on this point, and it remains to be seen whether governments will pick up on this point. There seem to be much to commend the idea that legislative schemes need to made more systematic to ensure that consultation is carried out effectively and to minimize the prospects of unjustifiable infringement of aboriginal rights. VIII. The Role of Injunctions 40. Several parties argued that the Government should not be saddled with a consultation obligation, since aboriginal people could always seek injunctions if they needed interim relief prior to establishing the scope of their rights. The Court dealt with this argument directly, holding that while injunctions were available, they were not very practical in cases of aboriginal rights claims. It was accepted that the balance of convenience test generally tips the balance in favour of protecting jobs and government revenues, making it more difficult for Aboriginal people to use the injunctive remedy to protect their claims in the pre-proof period. 41. One byproduct of this analysis may be to make recourse to injunctions less likely, as the inadequacies of this remedy in aboriginal right cases appear to have been endorsed by the Court. IX. Some Unanswered Questions 42. While many in British Columbia will consider this decision to be an end to a lengthy debate about the nature, timing and source of the consultation obligation, the Supreme Court regarded this case as just the first step in developing the law in relation to pre-proof obligations. 25 The Consultation Guidelines are referenced at para. 51 of Haida (SCC). The reference is not entirely accurate, as the Court indicates that British Columbia has had consultation guidelines in place since October 2002, whereas the Province in fact initiated such guidelines in the early 1990 s. The 2002 version is just the most recent iteration of the Guidelines.
13 13 The Court stated that the decision set out a general framework for understanding these issues. Some of the questions not addressed by the Court include: (i) When will permits be set aside for failure to consult and, where appropriate, accommodate? The Court does not address this issue, which did not have to be decided in either case. It seems clear that setting aside a permit remains a possible remedy in these cases, but the fact that the Court reversed the decision in the Taku River Tlingit case may suggest that it requires a serious departure from the appropriate conduct to support such an extreme remedy. (ii) Who is to be consulted? The Court does not address this issue, presumably because the point was clear in the two cases before the Court. The decision seems to indicate that any aboriginal group making a claim of rights or title should be consulted. Weak or peripheral claims can be addressed by the minimal consultation of notice. (iii) Who pays for the consultation costs of the aboriginal people? A persistent practical problem in this area is the lack of financial and resource capacity of bands when consulted on complex projects. The Court does not address this issue. 43. While these and other questions remain, the Court has provided welcome clarification of the nature and scope of the obligation to consult and accommodate prior to proof of aboriginal rights or title. John J.L. Hunter Q.C. January, 2005
QuÉbec AMERINDIANS AND INUIT OF QUÉBEC INTERIM GUIDE FOR CONSULTING THE ABORIGINAL COMMUNITIES
QuÉbec AMERINDIANS AND INUIT OF QUÉBEC INTERIM GUIDE FOR CONSULTING Interministerial working group on the consultation of the Aboriginal people Ministère du Développement durable, de l Environnement et
KINDER MORGAN CANADA LIMITED: BRIEF ON LEGAL RISKS FOR TRANS MOUNTAIN
West Coast Environmental Law Association 200-2006 W.10 th Avenue Vancouver, BC Coast Salish Territories wcel.org 2017 KINDER MORGAN CANADA LIMITED: BRIEF ON LEGAL RISKS FOR TRANS MOUNTAIN May 29, 2017
LEGAL DEVELOPMENTS IN THE DUTY TO CONSULT November, Meaghan Conroy Associate, Ackroyd LLP
ACKROYD LLP LEGAL DEVELOPMENTS IN THE DUTY TO CONSULT November, 2009 Meaghan Conroy Associate, Ackroyd LLP Since the release of The Supreme Court of Canada decisions in Haida 1, Taku 2 and Mikisew 3, Canadian
IN THE SUPREME COURT OF BRITISH COLUMBIA
IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: Between: And The Council of the Haida Nation v. British Columbia, 2017 BCSC 1665 The Council of the Haida Nation and Peter Lantin, suing on his own behalf
A Turning Point In The Civilization
Kichesipirini Algonquin First Nation Kichi Sibi Anishnabe / Algonquin Nation Canada By Honouring Our Past We Determine Our Future algonquincitizen@hotmail.com A Turning Point In The Civilization Re: Ottawa
PROPHET RIVER FIRST NATION AND WEST MOBERLY FIRST NATIONS. and
Date: 20170123 Docket: A-435-15 Citation: 2017 FCA 15 CORAM: TRUDEL J.A. BOIVIN J.A. DE MONTIGNY J.A. BETWEEN: PROPHET RIVER FIRST NATION AND WEST MOBERLY FIRST NATIONS Appellants and ATTORNEY GENERAL
Legal Review of Canada s Interim Comprehensive Land Claims Policy
TO: FROM: SUBJECT: Union of B.C. Indian Chiefs Bruce McIvor Legal Review of Canada s Interim Comprehensive Land Claims Policy DATE: November 4, 2014 This memorandum provides a legal review of Canada s
The MacMillan Bloedel Settlement Agreement
The MacMillan Bloedel Settlement Agreement Submissions to Mr. David Perry Jessica Clogg, Staff Counsel West Coast Environmental Law JUNE 30, 1999 Introduction The following submissions build upon and clarify
Provincial Jurisdiction After Delgamuukw
2.1 ABORIGINAL TITLE UPDATE Provincial Jurisdiction After Delgamuukw These materials were prepared by Albert C. Peeling of Azevedo & Peeling, Vancouver, B.C. for Continuing Legal Education, March, 1998.
ABORIGINAL TITLE AND RIGHTS: FOUNDATIONAL PRINCIPLES AND RECENT DEVELOPMENTS
ABORIGINAL TITLE AND RIGHTS: FOUNDATIONAL PRINCIPLES AND RECENT DEVELOPMENTS Maria Morellato,Q.C. Mandell Pinder 2009 Constitutional & Human Rights Conference The McLachlin Court s First Decade: Reflections
SPECIFIC CLAIMS TRIBUNAL TRIBUNAL DES REVENDICATIONS PARTICULIÈRES
FILE NO.: SCT-7005-11 CITATION: 2016 SCTC 12 DATE: 20160722 SPECIFIC CLAIMS TRIBUNAL TRIBUNAL DES REVENDICATIONS PARTICULIÈRES BETWEEN: ) ) POPKUM FIRST NATION ) ) ) Claimant ) ) and ) ) HER MAJESTY THE
Popkum Indian Band Interim Agreement on Forest & Range Opportunities (the "Agreement'J) Between: The Popkum Indian Band
Popkum Indian Band Interim Agreement on Forest & Range Opportunities (the "Agreement'J) Between: The Popkum Indian Band As Represented by Chief and Council (the "Popkum Indian Band") And Her Majesty the
Queen s University Opinion Letter Team 6 Oil Drum Industries February 15, Kawaskimhon Moot
INTRODUCTION Queen s University Opinion Letter Team 6 Oil Drum Industries February 15, 2008 2008 Kawaskimhon Moot Treaty 8 was signed in 1899 by various Aboriginal communities across western Canada, including
April 6, RSC, 1985, c N-22. SC 1992, c 37. SC 2012, c 19.
West Coast Environmental Law Bill C-69 Achieving the Next Generation of Impact Assessment Brief to the House of Commons Standing Committee on Environment and Sustainable Development April 6, 2018 Thank
IN THE SUPREME COURT OF CANADA (ON APPEAL FROM THE FEDERAL COURT OF APPEAL)
BETWEEN: IN THE SUPREME COURT OF CANADA (ON APPEAL FROM THE FEDERAL COURT OF APPEAL) cmppewas OF THE THAMES FIRST NATION -and- File No. 36776 APPLICANT (Appellant) ENBRIDGE PIPELINES INC. THE NATIONAL
IN THE SUPREME COURT OF BRITISH COLUMBIA
IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: Between: Cowichan Tribes v. Canada (Attorney General), 2016 BCSC 1660 Date: 20160908 Docket: 14-1027 Registry: Victoria Cowichan Tribes, Squtxulenuhw,
Case Name: R. v. Stagg. Between Her Majesty the Queen, and Norman Stagg. [2011] M.J. No MBPC 9. Manitoba Provincial Court
Page 1 Case Name: R. v. Stagg Between Her Majesty the Queen, and Norman Stagg [2011] M.J. No. 56 2011 MBPC 9 Manitoba Provincial Court B.M. Corrin Prov. Ct. J. February 11, 2011. (19 paras.) Counsel: Nathaniel
MEMORANDUM. Douglas White and Dr. Roshan Danesh. Tsilhqot in Nation and the British Columbia Treaty Process
MEMORANDUM To: From: Re: Chiefs Executive Council, Okanagan Nation Alliance Douglas White and Dr. Roshan Danesh Tsilhqot in Nation and the British Columbia Treaty Process Date: February 12, 2016 A. QUESTION
First Nations Child and Family Caring Society of Canada. - and - Assembly of First Nations. - and - Canadian Human Rights Commission.
Canadian Human Rights Tribunal Tribunal canadien des droits de la personne Citation: 2016 CHRT 10 Date: April 26, 2016 File No.: T1340/7008 Between: First Nations Child and Family Caring Society of Canada
British Columbia's Tobacco Litigation and the Rule of Law
The Peter A. Allard School of Law Allard Research Commons Faculty Publications (Emeriti) 2004 British Columbia's Tobacco Litigation and the Rule of Law Robin Elliot Allard School of Law at the University
Gwaii Haanas: Working Together to Achieve Common Goals
Gwaii Haanas: Working Together to Achieve Common Goals Ernie Gladstone, Field Unit Superintendent, Gwaii Haanas National Park, Reserve and Haida Heritage Site, 60 Second Beach Road, Skidegate (Haida Heritage
STEPPING INTO CANADA S SHOES: TSILHQOT IN, GRASSY NARROWS AND THE DIVISION OF POWERS
STEPPING INTO CANADA S SHOES: TSILHQOT IN, GRASSY NARROWS AND THE DIVISION OF POWERS Bruce McIvor & Kate Gunn * I. INTRODUCTION The Tsilhqot in and Grassy Narrows decisions represent an about-face in the
Weaving a Third Strand Into the Braid of Aboriginal Crown Relations:
Weaving a Third Strand Into the Braid of Aboriginal Crown Relations: Legal Obligations to Finance Aboriginal Governments Negotiated in Canada RAMI SHOUCRI I INTRODUCTION 97 II THE RIGHT TO SELF-GOVERNMENT
IN THE SUPREME COURT OF BRITISH COLUMBIA
Date: 19980710 Docket: S046974 Registry: New Westminster IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: DEREK PAGET AND PAKAR HOMES LTD. PETITIONER AND: VERNOR KARPINSKI RESPONDENT REASONS FOR JUDGMENT
Enforcement of International Arbitral Awards in Canada
McCarthy Tétrault LLP PO Box 48, Suite 5300 Toronto-Dominion Bank Tower Toronto ON M5K 1E6 Canada Tel: 416-362-1812 Fax: 416-868-0673 Enforcement of International Arbitral Awards in Canada DAVID I. W.
Treaty Litigation: Some Common Pitfalls and Obstacles
Treaty Litigation: Some Common Pitfalls and Obstacles Written By: Christopher Devlin and Tim Watson 1 Prepared for: Canadian Bar Association National Aboriginal Law Conference April 29, 2011 (Winnipeg,
R. v. Morris: A Shot in the Dark and Its Repercussions
R. v. Morris: A Shot in the Dark and Its Repercussions KERRY WILKINS * I THE SCOPE OF THE TSARTLIP TREATY RIGHT TO HUNT 4 II THE LEGITIMATE REACH OF PROVINCIAL LEGISLATION 10 Division of Powers: The Limits
Canada s Positions on the Adoption of the U.N. Declaration on the Rights of Indigenous Peoples: Concerns and Recommendations
August 21, 2006 The Honourable Jim Prentice Minister of Indian Affairs and Northern Development House of Commons Ottawa, Ontario K1A 0A6 Dear Minister Prentice: Re: Canada s Positions on the Adoption of
Reconciliation and the Supreme Court: The Opposing Views of Chief Justices Lamer and McLachlin
Osgoode Hall Law School of York University Osgoode Digital Commons Articles & Book Chapters Faculty Scholarship 2003 Reconciliation and the Supreme Court: The Opposing Views of Chief Justices Lamer and
The Honour of the Crown: Making Sense of Crown Liability Doctrine in Crown/Aboriginal Law in Canada
The Honour of the Crown: Making Sense of Crown Liability Doctrine in Crown/Aboriginal Law in Canada A Thesis Submitted to the College of Graduate Studies and Research In Partial Fulfillment of the Requirements
SUPREME COURT OF CANADA. CITATION: R. v. Punko, 2012 SCC 39 DATE: DOCKET: 34135, 34193
SUPREME COURT OF CANADA CITATION: R. v. Punko, 2012 SCC 39 DATE: 20120720 DOCKET: 34135, 34193 BETWEEN: AND BETWEEN: John Virgil Punko Appellant and Her Majesty The Queen Respondent Randall Richard Potts
IN THE SUPREME COURT OF BRITISH COLUMBIA
IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: R. v. Nuttall, 2016 BCSC 73 Regina v. John Stuart Nuttall and Amanda Marie Korody Date: 20160111 Docket: 26392 Registry: Vancouver Restriction on Publication:
Lil wat Nation Land Use Referral Consultation Policy
Lil wat Nation Land Use Referral Consultation Policy Ratified by Chief and Council February 21, 2012 The Líl, wat Nation P.O. BOX 602, MOUNT CURRIE, BRITISH COLUMBIA V0N 2K0 PHONE 1.604.894.6115 FAX 1.604.894.6841
Review of Administrative Decisions Involving Charter Rights: The Shortcomings of the SCC Decision in Doré
Review of Administrative Decisions Involving Charter Rights: The Shortcomings of the SCC Decision in Doré February 24, 2014, OTTAWA Distinct But Overlapping: Administrative Law and the Charter Over the
CITATION: Ontario Federation of Anglers and Hunters v. Ontario, 2015 ONSC 7969 COURT FILE NO.: 318/15 DATE:
CITATION: Ontario Federation of Anglers and Hunters v. Ontario, 2015 ONSC 7969 COURT FILE NO.: 318/15 DATE: 20151218 SUPERIOR COURT OF JUSTICE - ONTARIO RE: ONTARIO FEDERATION OF ANGLERS AND HUNTERS, Applicant
Administrative Penalties
Administrative Penalties Final Report March 2012 Administrative penalties are a mechanism for enforcing compliance with regulatory legislation. They are monetary penalties assessed and imposed by a regulator
Changes to Senate Procedures in the 113 th Congress Affecting the Operation of Cloture (S.Res. 15 and S.Res. 16)
Changes to Senate Procedures in the 113 th Congress Affecting the Operation of Cloture (S.Res. 15 and S.Res. 16) Elizabeth Rybicki Specialist on Congress and the Legislative Process March 13, 2013 CRS
McNeil Disclosure Packages
TRANSIT POLICE MCNEIL DISCLOSURE PACKAGES Effective Date: Interim Policy February 18, 2010 Revised Date: January 31, 2014 Reviewed Date: Review Frequency: As Required Office of Primary Responsibility:
SUPREME COURT OF NOVA SCOTIA Citation: Maxwell Properties Ltd. v. Mosaik Property Management Ltd., 2017 NSSC 81
SUPREME COURT OF NOVA SCOTIA Citation: Maxwell Properties Ltd. v. Mosaik Property Management Ltd., 2017 NSSC 81 Date: 20170316 Docket: Hfx No. 458069 Registry: Halifax Between: Maxwell Properties Limited
Ingles v. The Corporation of the City of Toronto Decision of the Supreme Court of Canada dated March 2, 2000
Ingles v. The Corporation of the City of Toronto Decision of the Supreme Court of Canada dated March 2, 2000 (City Council at its regular meeting held on October 3, 4 and 5, 2000, and its Special Meetings
Indexed as: Campbell v. British Columbia (Attorney General)
Page 1 Indexed as: Campbell v. British Columbia (Attorney General) Between Gordon M. Campbell, Michael G. de Jong and P. Geoffrey Plant, plaintiffs, and Attorney General of British Columbia, Attorney General
REVIEW REPORT FI December 29, 2015 Department of Finance
Office of the Information and Privacy Commissioner for Nova Scotia Report of the Commissioner (Review Officer) Catherine Tully REVIEW REPORT FI-13-28 December 29, 2015 Department of Finance Summary: The
COURT OF APPEAL FOR BRITISH COLUMBIA
COURT OF APPEAL FOR BRITISH COLUMBIA Citation: Between: And BC Freedom of Information and Privacy Association v. British Columbia (Attorney General), 2015 BCCA 172 B.C. Freedom of Information and Privacy
Conflicts Of Interest
Conflicts Of Interest Dan MacDonald November 8, 2012 Today s Agenda What is the legal test that governs external counsel in analyzing conflicts of interest? Duty of Loyalty Three key SCC decisions and
The Crown's Fiduciary Obligations in the Era of Aboriginal Self-Government
Osgoode Hall Law School of York University Osgoode Digital Commons Articles & Book Chapters Faculty Scholarship 2009 The Crown's Fiduciary Obligations in the Era of Aboriginal Self-Government Kent McNeil
Aboriginal Law 101. Saturday Morning at the Law School. David Laidlaw, Canadian Institute of Resources Law University of Calgary February 20, 2016
Saturday Morning at the Law School Aboriginal Law 101 David Laidlaw, Canadian Institute of Resources Law University of Calgary February 20, 2016 SPONSORED BY Current Aboriginal Issues in Canada Objectives
Complaints against Government - Judicial Review
Complaints against Government - Judicial Review CHAPTER CONTENTS Introduction 2 Review of State Government Action 2 What Government Actions may be Challenged 2 Who Can Make a Complaint about Government
The Arbitration Act, 1992
1 The Arbitration Act, 1992 being Chapter A-24.1* of the Statutes of Saskatchewan, 1992 (effective April 1, 1993) as amended by the Statutes of Saskatchewan, 1993, c.17; 2010, c.e-9.22; 2015, c.21; and
Why use this slogan anywhere else?
Intellectual Property and Litigation Bulletin February 2017 Why use this slogan anywhere else? What happens when the owner of one of Canada s catchiest jingles faces a new marketing campaign from a long-standing
RE: The Board s refusal to allow public access to the Kinder Morgan Trans Mountain Hearings
Direct Line: 604-630-9928 Email: Laura@bccla.org BY EMAIL January 20, 2016 Peter Watson, Chair National Energy Board 517 Tenth Avenue SW Calgary, Alberta T2R 0A8 RE: The Board s refusal to allow public
Order F13-01 MINISTRY OF HEALTH AND MINISTRY OF CITIZENS SERVICES AND OPEN GOVERNMENT. Michael McEvoy, Assistant Commissioner.
Order F13-01 MINISTRY OF HEALTH AND MINISTRY OF CITIZENS SERVICES AND OPEN GOVERNMENT Quicklaw Cite: [2013] B.C.I.P.C.D. No. 1 CanLII Cite: 2013 BCIPC No. 1 Michael McEvoy, Assistant Commissioner January
2009 Bill 36. Second Session, 27th Legislature, 58 Elizabeth II THE LEGISLATIVE ASSEMBLY OF ALBERTA BILL 36 ALBERTA LAND STEWARDSHIP ACT
2009 Bill 36 Second Session, 27th Legislature, 58 Elizabeth II THE LEGISLATIVE ASSEMBLY OF ALBERTA BILL 36 ALBERTA LAND STEWARDSHIP ACT THE MINISTER OF SUSTAINABLE RESOURCE DEVELOPMENT First Reading.......................................................
Order F10-01 GREATER VANCOUVER REGIONAL DISTRICT. Michael McEvoy, Adjudicator. January 7, 2010
Order F10-01 GREATER VANCOUVER REGIONAL DISTRICT Michael McEvoy, Adjudicator January 7, 2010 Quicklaw Cite: [2010] B.C.I.P.C.D. No. 1 CanLII Cite: 2010 BCIPC 1 Document URL: http://www.oipc.bc.ca/orders/2010/orderf10-01.pdf
GENERAL RULES ABOUT COSTS
PRACTICE DIRECTION PART 44 DIRECTIONS RELATING TO PART 44 GENERAL RULES ABOUT COSTS SECTION 7 SOLICITOR S DUTY TO NOTIFY CLIENT: RULE 44.2 7.1 For the purposes of rule 44.2 client includes a party for
IN THE HIGH COURT OF SOUTH AFRICA WESTERN CAPE HIGH COURT, CAPE TOWN AROMA MANAGEMENT SERVICES (PTY) LTD JUDGMENT DELIVERED ON 29 MAY 2009
IN THE HIGH COURT OF SOUTH AFRICA WESTERN CAPE HIGH COURT, CAPE TOWN In the matter between: CASE NO: 2625/2009 AROMA MANAGEMENT SERVICES (PTY) LTD Applicant and THE MINISTER OF TRADE AND INDUSTRY THE NATIONAL
Order F05-21 LAND AND WATER BRITISH COLUMBIA INC.
Order F05-21 LAND AND WATER BRITISH COLUMBIA INC. Celia Francis, Adjudicator July 12, 2005 Quicklaw Cite: [2005] B.C.I.P.C.D. No. 29 Document URL: http://www.oipc.bc.ca/orders/orderf05-21.pdf Office URL:
Syllabus. Canadian Constitutional Law
Syllabus Canadian Constitutional Law (Revised February 2015) Candidates are advised that the syllabus may be updated from time-to-time without prior notice. Candidates are responsible for obtaining the
IN THE SUPREME COURT OF NOVA SCOTIA Citation: Drescher v. Drescher Estate, 2007 NSSC 352. Docket: SH. No
Page 1 of 7 IN THE SUPREME COURT OF NOVA SCOTIA Citation: Drescher v. Drescher Estate, 2007 NSSC 352 Docket: SH. No. 278018 Date: 20071121 Registry: Halifax Between: Gisela Drescher, by her attorney Alex
INDIVISIBLE INJURIES
INDIVISIBLE INJURIES Amelia J. Staunton February 2011 1 CONTACT LAWYER Amelia Staunton 604.891.0359 astaunton@dolden.com 1 Introduction What happens when a Plaintiff, recovering from injuries sustained
The Crown Minerals Act
1 The Crown Minerals Act being Chapter C-50.2 of the Statutes of Saskatchewan, 1984-85- 86 (effective July 1, 1985) as amended by the Statutes of Saskatchewan, 1988-89, c.42; 1989-90, c.54; 1990-91, c.13;
Traditional Governance and Constitution Making among the Gitanyow
Traditional Governance and Constitution Making among the Gitanyow Prepared for the First Nations Governance Centre By Albert C. Peeling October 11, 2004 1 Traditional Governance and Constitution Making
Practice Guideline 9: Guideline for Arbitrators on Making Orders Relating to the Costs of the Arbitration
Practice Guideline 9: Guideline for Arbitrators on Making Orders Relating to the Costs of the Arbitration 1. Introduction 1.1 One of the most difficult and important functions which an arbitrator has to
Part 1 Interpretation
The New Limitation Act Explained Page 1 Part 1 Interpretation This Part defines terms and provides some general principles of interpretation for the new Limitation Act ( new Act ). Division 1 Definitions
Comments and observations received from Governments
Extract from the Yearbook of the International Law Commission:- 1997,vol. II(1) Document:- A/CN.4/481 and Add.1 Comments and observations received from Governments Topic: International liability for injurious
On December 14, 2011, the B.C. Court of Appeal released its judgment
LIMITATION PERIODS ON DEMAND PROMISSORY NOTES: THE SIGNIFICANCE OF MAKING THE NOTE PAYABLE A FIXED PERIOD AFTER DEMAND By Georges Sourisseau and Russell Robertson On December 14, 2011, the B.C. Court of
COURT OF APPEAL FOR BRITISH COLUMBIA
COURT OF APPEAL FOR BRITISH COLUMBIA Citation: Director of Civil Forfeiture v. Lloydsmith, 2014 BCCA 72 Date: 20140221 Docket: CA040891; CA040896 Civil Forfeiture Action in Rem Against The Lands and Structures
The Child and Family Services Act
1 The Child and Family Services Act being Chapter C-7.2 of the Statutes of Saskatchewan, 1989-90 (consult Table of Saskatchewan Statutes for effective date) as amended by the Statutes of Saskatchewan,
Syllabus. Administrative Law. (Revised January 2017) Candidates are advised that the syllabus may be updated from time-to-time without prior notice.
Syllabus Administrative Law (Revised January 2017) Candidates are advised that the syllabus may be updated from time-to-time without prior notice. Candidates are responsible for obtaining the most current
Substantial and Unreasonable Injurious Affection after Antrim Truck Centre Ltd. v. Ontario (Transportation)
May 2013 Municipal Law Section Substantial and Unreasonable Injurious Affection after Antrim Truck Centre Ltd. v. Ontario (Transportation) By Scott McAnsh Antrim Truck Stop is located just off Highway
Second medical use or indication claims
Question Q238 National Group: Title: Contributors: Reporter within Working Committee: Canada Second medical use or indication claims Matthew ZISCHKA Santosh CHARI Carol HITCHMANN Roseanne CALDWELL Charles
Professional Discipline Procedural Handbook
Professional Discipline Procedural Handbook Revised Edition March 2005 Table of Contents PREAMBLE... 6 DEFINITIONS... 6 1 ADMINISTRATION-DISCIPLINE COMMITTEE... 8 1.1 Officers of the Committee... 7 1.2
ARTICLE 1 - INTERPRETATION
Popkum Indian Band Forest & Range Consultation and Revenue Sharing Agreement (FCRSA) (the Agreement ) Between: Popkum Indian Band As Represented by Chief and Council (Popkum Indian Band or Popkum First
IN THE SUPREME COURT OF BRITISH COLUMBIA
IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: Between: And: Chingee v. British Columbia, 2016 BCSC 760 Harry Chingee Date: 20160428 Docket: 1343188 Registry: Prince George Plaintiff (1) Her Majesty
TSILHQOT IN NATION v. BRITISH COLUMBIA: IS IT A GAME CHANGER IN CANADIAN ABORIGINAL TITLE LAW AND CROWN-INDIGENOUS RELATIONS?
TSILHQOT IN NATION v. BRITISH COLUMBIA: IS IT A GAME CHANGER IN CANADIAN ABORIGINAL TITLE LAW AND CROWN-INDIGENOUS RELATIONS? CONTENTS by Bradford W. Morse* I Introduction 65 II Background to the Decision
(LTA). We have decided to approach this topic by exploring the continuum of where we
Tansi! As members of the Saulteau First Nation, you have sought our advice on the current situation facing your people with respect to the Lheidli T enneh Agreement (LTA). We have decided to approach this
ADMINISTRATIVE FAIRNESS GUIDEBOOK
ADMINISTRATIVE FAIRNESS GUIDEBOOK Introduction This guidebook has been created to help you learn how the Alberta Ombudsman investigates complaints of unfair treatment by Alberta government departments,
For further information into the expanded analysis developed from the initial table and the broader findings of the research, please refer to:
An Evaluation of Ontario Provincial Land Use and Resource Management Policies and Their Intersection with First Nations with Respect to Manifest and Latent Content - Summary Table: Author s Note December
COURT OF APPEAL FOR BRITISH COLUMBIA
COURT OF APPEAL FOR BRITISH COLUMBIA Citation: Between: And Belron Canada Inc. v. TCG International Inc., 2009 BCCA 577 Belron Canada Incorporated/Belron Canada Incorporee Date: 20091217 Docket: CA037131
ALBERTA INFORMATION AND PRIVACY COMMISSIONER. Regional Municipality of Wood Buffalo (OIPC File Reference ) November 29, 2017
ALBERTA INFORMATION AND PRIVACY COMMISSIONER Request for Authorization to Disregard an Access Request under section 55(1) of the Freedom of Information and Protection of Privacy Act Regional Municipality
The Attorney General of Quebec. Régent Sioui, Conrad Sioui, Georges Sioui and Hugues Sioui
R. v. Sioui, [1990] 1 S.C.R. 1025 The Attorney General of Quebec v. Régent Sioui, Conrad Sioui, Georges Sioui and Hugues Sioui Appellant Respondents and The Attorney General of Canada and the National
IN THE SUPREME COURT OF BRITISH COLUMBIA
Citation: Gringmuth v. The Corp. of the Dist. of North Vancouver Date: 20000524 2000 BCSC 807 Docket: C995402 Registry: Vancouver IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: AXEL GRINGMUTH PLAINTIFF
Submission to the Foreign Affairs, Defence and Trade Committee on the New Zealand Intelligence and Security Bill
Submission to the Foreign Affairs, Defence and Trade Committee on the New Zealand Intelligence and Security Bill Contact Persons Janet Anderson-Bidois Chief Legal Adviser New Zealand Human Rights Commission
Decision F07-03 MINISTRY OF ECONOMIC DEVELOPMENT. David Loukidelis, Information and Privacy Commissioner. June 22, 2007
Decision F07-03 MINISTRY OF ECONOMIC DEVELOPMENT David Loukidelis, Information and Privacy Commissioner June 22, 2007 Quicklaw Cite: [2007] B.C.I.P.C.D. No. 14 Document URL: http://www.oipc.bc.ca/orders/other_decisions/decisionfo7-03.pdf
AMERICAN INTERNATIONAL GROUP, INC. BY-LAWS. Amended November 16, 2015 ARTICLE I. Stockholders
AMERICAN INTERNATIONAL GROUP, INC. BY-LAWS Amended November 16, 2015 ARTICLE I Stockholders Section 1.1. Annual Meetings. An annual meeting of stockholders shall be held for the election of directors at
IN THE COURT OF APPEAL THE ATTORNEY GENERAL OF ST. CHRISTOPHER AND NEVIS THE DIRECTOR OF PUBLIC PROSECUTIONS THE SUPERINTENDENT OF PRISONS
SAINT CHRISTOPHER AND NEWS 1 CIVIL APPEAL NO. 1 OF 1997 BETWEEN: IN THE COURT OF APPEAL THE ATTORNEY GENERAL OF ST. CHRISTOPHER AND NEVIS THE DIRECTOR OF PUBLIC PROSECUTIONS THE SUPERINTENDENT OF PRISONS
Patent Enforcement in India
Patent Enforcement in India Intellectual property assets are touted as the cornerstone of competitiveness in international trade and are the driving factors behind socio-economic development in India.
THE LABOUR COURT OF SOUTH AFRICA, JOHANNESBURG JUDGMENT. MICHAEL KAWALYA-KAGWA Applicant
THE LABOUR COURT OF SOUTH AFRICA, JOHANNESBURG JUDGMENT Not reportable Case no: J 2406/16 In the matter between: MICHAEL KAWALYA-KAGWA Applicant and DEVELOPMENT BANK OF SOUTHERN AFRICA Respondent Heard:
The Law Society of British Columbia In the matter of the Legal Profession Act, SBC 1998, c.9 and a hearing concerning AARON MURRAY LESSING.
2012 LSBC 19 Report issued: May 28, 2012 Citations issued: March 23, 2011 and July 28, 2011 The Law Society of British Columbia In the matter of the Legal Profession Act, SBC 1998, c.9 and a hearing concerning
DEVELOPMENTS IN JUDICIAL REVIEW IN THE CONTEXT OF IMMIGRATION CASES. A Comment Prepared for the Judicial Conference of Australia's Colloquium 2003
DEVELOPMENTS IN JUDICIAL REVIEW IN THE CONTEXT OF IMMIGRATION CASES A Comment Prepared for the Judicial Conference of Australia's Colloquium 2003 DARWIN - 30 MAY 2003 John Basten QC Dr Crock has provided
British Columbia after the Delgamuukw Decision: Land Claims and other Processes
British Columbia after the Delgamuukw Decision: Land Claims and other Processes British Columbia after the Delgamuukw Decision: Land Claims and other Processes 239 GURSTON DACKS Department of Political
Fundamentals of Judicial Review. Prepared For: The Legal Education Society of Alberta
Fundamentals of Judicial Review Prepared For: The Legal Education Society of Alberta For Presentation in: Calgary, Alberta September 16, 2014 September 17, 2014 Introduction Prepared For: Legal Education
Information Brief. British Columbia Law Institute Workplace Dispute Resolution Consultation. British Columbia Human Rights Tribunal
British Columbia Human Rights Tribunal Suite 1170, 605 Robson St. Vancouver BC V6B 5J3 Phone: (604) 775-2000 Toll Free: 1-888-440-8844 TTY: (604) 775-2021 FAX: (604) 775-2020 Internet: www.bchrt.bc.ca
CHARTER 1. PREAMBLE. 1.4 This Charter can only be amended by a three quarters majority vote of the Council. 2. PURPOSES AND AIMS OF IACS
CHARTER Adopted at a meeting of Council on 27 October 2009 2009 Rev 1: clarification in 4.13 and in Annex 3, 1.2 adopted by correspondence 15 August 2011; also references to QSCS transition period deleted.
STANDING RULES OF ORDER
STANDING RULES OF ORDER OF THE CENTRAL COUNCIL TLINGIT AND HAIDA INDIAN TRIBES OF ALASKA TABLE OF CONTENTS PAGE I. PURPOSE... 2 II. RULES OF ORDER... 2 III. WELCOME CEREMONY... 2 IV. REGISTRATION... 2
ON THE ADMINISTRATIVE PROCEDURE
UNITED NATIONS United Nations Interim Administration Mission in Kosovo UNMIK NATIONS UNIES Mission d Administration Intérimaire des Nations Unies au Kosovo PROVISIONAL INSTITUTIONS OF SELF GOVERNMENT Law
Federal Judicial Appointment Process
Federal Judicial Appointment Process CANADIAN BAR ASSOCIATION October 2005 865 Carling Avenue, Suite 500, Ottawa, Ontario K1S 5S8 Tel/Tél: 613 237-2925 Toll free/sans frais: 1 800 267-8860 Fax/Télécop:
IN THE SUPREME COURT OF INDIA CRIMINAL APPELLATE JURISDICTION. CRIMINAL APPEAL NO OF 2017 (Arising out of SLP(Crl.) No.
REPORTABLE IN THE SUPREME COURT OF INDIA CRIMINAL APPELLATE JURISDICTION CRIMINAL APPEAL NO. 1534 OF 2017 (Arising out of SLP(Crl.) No.1439 of 2017) N. Harihara Krishnan Appellant Versus J. Thomas Respondent
CITY OF VANCOUVER DUTY TO ASSIST
AUDIT & COMPLIANCE REPORT F16-01 CITY OF VANCOUVER DUTY TO ASSIST Elizabeth Denham Information and Privacy Commissioner for British Columbia June 23, 2016 CanLII Cite: 2016 BCIPC 32 Quicklaw Cite: [2016]
IN THE SUPREME COURT OF BRITISH COLUMBIA
IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: Between: Gorenshtein v. British Columbia (Employment Standards Tribunal), 2013 BCSC 1499 Date: 20130819 Docket: S130604 Registry: Vancouver Tatiana Gorenshtein
Decision F Jay Fedorak, Adjudicator. November 23, 2011
Decision F11-04 COLLEGE OF PHYSICIANS AND SURGEONS OF BRITISH COLUMBIA Jay Fedorak, Adjudicator November 23, 2011 Quicklaw Cite: [2011] B.C.I.P.C.D. No. 40 CanLII Cite: 2011 BCIPC 40 Document URL: http://www.oipc.bc.ca/orders/section43/decisionf11-04.pdf