HomeMy WebLinkAboutP-2015-1619.Telford.16-5-25 DecisionPublic Service
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PSGB#P-2015-1619
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Jeffery Telford Complainant
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The Crown in Right of Ontario
(Ministry of Finance) Employer
BEFORE Kathleen G. O’Neil Chair
FOR THE
COMPLAINANT
Brian Johnston
Counsel
FOR THE EMPLOYER Roslyn Baichoo
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING March 4, 2016
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Decision
[1] This decision deals with a preliminary objection raised by the employer in regards
to the complaint of Jeffery Telford in which he contests his termination from
employment. The employer asks that the complaint be dismissed, as it was not
filed with the Board in the period required by regulation. The complainant asks
that his complaint be allowed to proceed to a hearing on the merits, as a matter
of procedural fairness in light of the seriousness of the issue of loss of
employment.
The factual context
[2] The facts necessary to this motion are essentially undisputed. The complainant
was terminated from employment by letter dated February 23, 2015 after over 20
years with the Ontario Financing Authority. Mr. Telford did not accept his
termination as just, and sought legal advice in the matter, initially from lawyer
Peter Eberhard. Three complaints, dated March 3, 31 and April 14, 2015, were
filed on Mr. Telford’s behalf, related to the dismissal and the payment of vacation
credits, seeking reinstatement and other remedies. There is no suggestion that
these were untimely.
[3] Mr. Telford and his lawyer met with the delegate of the Chair of the Public
Service Commission to discuss his complaints on April 21, 2015. A written
decision denying them was dated May 19, 2015 and received by Mr. Telford on
May 21, 2015. In an affidavit filed in support of his position on this motion, Mr.
Telford states that, having initiated the process by filing a grievance within
specific timelines, he was unaware that further time limits might apply. While he
did not direct his mind to timelines, he was confident that his lawyer had or would
comply with any necessary timelines. Having received the written decision, Mr.
Telford e-mailed his lawyer without delay, including a partially filled out complaint
form.
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[4] In reply to his e-mail, Mr. Telford received the shocking news from Mr.
Eberhard’s office that his lawyer had recently died. Mr. Telford informed his
contact person with the employer of the unfortunate news the same day, May 22,
2015, advising he was seeking new counsel. She responded promptly as well,
saying she was very sorry to hear the sad news, and asking Mr. Telford to let her
know when he had representation. Mr. Telford states that in sending the e-mail
as soon as he knew of Mr. Eberhard’s death, he was intending to make it clear to
the employer that he was proceeding with his application/appeal and that he
would need time to seek out and retain new counsel. He was not advised that
further action was required in any time-line, and if he had been so advised, he
states that he would have forwarded the partially completed application with the
explanation that the grounds would be forwarded by counsel once retained and
briefed.
[5] The Law Society of Upper Canada was appointed Trustee of Mr. Eberhard’s law
practice and through them Mr. Telford arranged for the delivery of his file to his
new counsel, Brian Johnston. Mr. Telford met with Mr. Johnston on July 7, 2015
and this application was filed on July 27, 2015. Mr. Telford states that he
asserted to his new lawyer his firm belief that no time limitation affected his
application to the PSGB.
Statutory References and Case Law Citation
[6] Relevant provisions of statute and regulations are attached as Appendix A for
ease of reference.
[7] Case law referred to by counsel is cited in Appendix B, all of which has been
carefully considered, whether or not referred to specifically in the discussion
below.
Considerations and Conclusions
[8] The issue to be decided is whether the complaint of Mr. Telford is one that the
Board is permitted to hear even though it was filed outside the time lines set out
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in the regulation. The Board only has the powers granted by the Public Service
of Ontario Act, and regulations made under that legislation, such as Regulation
378/07. That regulation sets out a very specific set of time lines or “windows” of
time in which steps must be taken to file complaints. A complaint about a
dismissal for cause, such as Mr. Telford’s, may be filed with the Board if the
preconditions referred to in s. 2 of Regulation 378/07 are fulfilled. The one at
issue here, found in s. 10 (1) of that regulation, requires that the complaint be
filed with this Board within 14 days after the end of the period of dispute
resolution provided for in the regulation.
[9] Section 9 of the Regulation describes the dispute resolution period, and when it
is deemed to have ended, i.e. the earlier of 30 days after the dispute resolution
meeting (if it is held within 30 days of the notice of complaint) or the date the
employer’s notice of its decision is given. In this case, a meeting was held on
April 21, 2015, which was within the thirty day period after the notice of at least
two of the complaints sent to the employer, so that the dispute resolution period
ends on the earlier of 30 days after the meeting on April 21, which is May 21, or
the date the employer’s notice of decision dated May 19, 2015 was given. Mr.
Telford received the employer’s decision on May 21. Mr. Telford had 14 days
after the end of the dispute resolution period to file his complaint with this Board.
It is common ground that the filing on July 27, 2015 falls outside the 14 day time
line.
[10] Employer counsel recognizes that the facts of this case are sympathetic to the
complainant, given the death of his lawyer shortly before the time lines in the
regulation expired. However, counsel argues that sympathetic facts are not
enough to overcome the mandatory nature of the time lines in the regulation.
Employer counsel argues that the Board, as a creature of statute, has to be
correct in interpreting the time lines set out there. By counsel’s count the referral
was over six weeks late. The Board is invited to take notice of the fact that the
Board regularly receives complaints from unrepresented individuals, and that a
lapse in representation does not give authority to change the regulation or extend
the time lines.
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[11] Counsel underlines that until the enactment of the current Regulation 378/07, the
Board had specific power to extend or abridge the time limits, but that it no longer
does. Unfortunate though it is that Mr. Eberhard passed away, it is the
employer’s position that it does not trigger any discretion in regards to the time
lines.
[12] In support of the proposition that the absence of the power to extend time lines in
the current regulation means the Board lacks the jurisdiction to do so, counsel
refers to Service Employees International Union, Local 204 v. Leisureworld
Nursing Homes Ltd., cited in Appendix B. In that decision, the Divisional Court
found it to be unambiguous that when words relating to the power to extend time
limits in provisions of collective agreements related to arbitration procedures, as
opposed to grievance procedures, were dropped from a statute, in that case, the
Labour Relations Act, arbitrators lost the right to extend those time limits. In a
similar fashion, it is the employer’s position that this Board no longer has the
power to extend the time limits set out in Regulation 378/07, given the removal of
the wording extending that power from the governing regulation. Counsel
emphasizes that the Court’s decision in Leisureworld that the arbitrator had no
jurisdiction to proceed on the basis of an untimely referral to arbitration, involved
facts dealing with someone’s livelihood, much like the present case.
Nonetheless, the Court agreed with the arbitrator’s decision that there was no
longer any discretion to extend or amend the time lines, as the language granting
the discretion had been removed when the legislation changed.
[13] Counsel notes that the Board has adopted a similar approach in decisions such
as St. Amant and The Crown in Right of Ontario (Ministry of Community Safety
and Correctional Services), Hasted and Berezowsky and The Crown in Right of
Ontario (Ministry of Community Safety and Correctional Services), and
Burkholder and The Crown in Right of Ontario (Ministry of Community Safety and
Correctional Services), cited in Appendix B. As well, counsel cites a decision of
the Ontario Labour Relations Board (OLRB), Hall and Beauchamp, cited in
Appendix B. In that case, through no fault of the applicant, a mandatory deadline
for an appeal under the Occupational Health and Safety Act was missed by 24
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hours through inadvertence of counsel. The OLRB made clear it would have
extended the time lines if it had the power, given the facts of that case, but found
that its power to determine its own practice and procedure did not give it the
ability to do so in the face of a violation of a statutory time line.
[14] Further, counsel submits the employer had no obligation to direct Mr. Telford as
to the time limits, but in any event the employer did refer him to Regulation
378/07 when it advised him of his right to grieve the decision in the termination
letter. Reference is also made to it on the Board’s complaint form, known as
Form 1, which he downloaded after he received the employer’s decision.
Nonetheless, in the employer’s view, the fact that the employer might have given
information about the regulation does not get over the statutory prohibitions. The
employer submits that the Board simply does not have the discretion or equitable
power to grant anything such as an extension of the time limits, as requested by
the applicant.
[15] By contrast, complainant’s counsel invited a different focus, based on the themes
of estoppel/waiver and procedural fairness or natural justice.
[16] Referring to the chronology set out above, counsel emphasises that on May 22,
2014 when Mr. Telford found himself without a lawyer, but clearly wanting to
proceed with his case, he did what any reasonable person would do - he
contacted the other side to let them know of the development. In communicating
that he would let the employer know who counsel was when he found someone,
he was clearly communicating that he wanted to proceed, but that being
unrepresented, he needed more time to get counsel in order to proceed. Counsel
submits that he was clearly asking for an indulgence to proceed because of Mr.
Eberhard’s death.
[17] Noting that the response from the employer raised no concern, counsel submits
that the employer was essentially saying, “Please let me know; we understand
your problem; it’s not a problem from the employer’s point of view”. The employer
could have come back and said we are relying on the time lines, but they did not.
Counsel submits that they were not heartless; they granted the indulgence
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requested. Counsel argues that Mr. Telford was entitled to rely on that as an
arrangement that he had time to get a new lawyer. It is the complainant’s
position that such an arrangement creates an estoppel against the employer, so
that it should not be permitted to raise a timeliness issue.
[18] In support of his submissions, complainant’s counsel refers to Ryan v. Moore
(Cabot Insurance), cited in Appendix B, which provides a review by the Supreme
Court of Canada of the law of estoppel. Counsel underlines that acquiescence,
and even mere silence, can give rise to an estoppel. Further, counsel asserts
that there was more than that here, that there was an express representation,
and nothing to the contrary. No employer representative said in any way that
there was any problem with the matter being continued. In counsel’s view, this
establishes one of the essential elements of estoppel, detrimental reliance. The
idea is that one party would suffer detriment if the other were permitted to act in a
manner inconsistent with their representation. Counsel emphasizes that, if Mr.
Telford’s complaint is not permitted to proceed, he suffers the detriment of the
loss of the opportunity to have a remedy like reinstatement.
[19] Counsel submits that the facts here demonstrate the elements referred to by the
court as necessary for estoppel, including a shared assumption of fact and
detrimental reliance such that it would be unfair to allow the employer to depart
from the common assumption. It is counsel’s submission that the parties agreed
to waive time lines, so that it is not now open to the employer to say that Mr.
Telford has breached them.
[20] In terms of procedural fairness and natural justice, counsel submits that
administrative tribunals have to give deference to procedural fairness and natural
justice, such as the case of Prassad v.Canada (Minister of Employment and
Immigration), cited in Appendix B. Fairness in human terms would dictate that a
tribunal would do whatever it can to see to it that Mr. Telford’s right to access the
Board and be heard on the merits not be derailed by events beyond his control,
in the complainant’s view.
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[21] Counsel emphasizes that the importance of the issue is highly relevant to what
procedures are sufficient to provide natural justice. The law is clear that the
more that is at stake, the more there is a duty to apply procedures and practices
to not be unfair to the applicant.
[22] In the present case, counsel submits there is a contest between the right to
counsel and the wording of the time limit in the regulations. In the complainant’s
view, if it comes down to a conflict between right to counsel and a procedural
provision, the board should not give paramountcy to the provision that would
deprive him of counsel.
[23] In terms of the regulation itself, counsel observes that Regulation 977 provided
that the Board could extend time lines, but did not give any criteria. Counsel
notes that the current regulation is simply silent on the issue; it does not really
revoke the power to extend time limits. Counsel submits that the board is back in
the position prior to Regulation 977, when it was free to control its own
procedure, including, in appropriate circumstances, to amend the time lines to
allow fairness.
[24] Counsel’s review of the provisions of Regulation 378/07 emphasized its
complexity. Noting that s. 8 of the current regulation gives a 14 day period to
deliver notice of intent to file a complaint to either the Minister or the Chair of the
Public Service Commission, counsel queried, what would happen if a
complainant sent it to the wrong place? Is the consequence of that that he is
completely out of luck - that the mandatory time frames apply and the person
loses his grievance? Or that a complainant loses the right to complain by filing
too early? Counsel offers such examples as unjust results, which demonstrate
why the board needs the power to control its own procedure.
[25] Further, counsel submits that the regulation is hard to read to the point that he
invites a finding that it is so non-functional and inconsistent with the Board’s
mandate that it should not be treated as binding. For instance, control of the time
lines is transferred from the complainant to a date to be determined by the action
or non-action of the deputy or the deputy’s delegate. Counsel notes that if the
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deputy announces the intention to have a meeting within the thirty days, and then
it does not occur within that time line, the time lines change again, creating
further opportunity for the complaint’s right to be heard to be defeated.
[26] Counsel remarks on what he saw as a further oddity, in that if the deputy does
hold a meeting, but does not give a decision within 30 days, the complainant
either loses his right to grieve by waiting to hear what the decision is, or is
required to appeal from a decision that he does not have, which could even be in
his favour. As well, counsel notes that the regulation does not say there is a
penalty or specify what the consequences are if it is not complied with. In
counsel’s view, natural justice and procedural fairness are much more reliable
guides as to how missed time lines should be treated.
[27] In reply, employer counsel emphasizes that, even though the regulation may
appear confusing initially, the Board’s case law has clarified it. Counsel refers to
the Board’s decision in Burkholder, cited in Appendix B, which, in the employer’s
view, clears up any doubt about s. 8 of the regulation, in a case where, like Mr.
Telford’s, the delay is at the stage of referral to arbitration of a challenge to a
discharge. Employer counsel submits that whatever counsel for the complaint
thinks the legislation meant prior to the predecessor of the current legislation, the
current jurisprudence leaves no doubt that there is no jurisdiction to entertain this
matter in the face of the employer’s objection. Counsel underlines that the
change in the regulation was not limited to the removal of the express power to
extend time limits, but also involved a change in the wording of the time limits
themselves, to wording that has been found to be clearly mandatory.
[28] Acknowledging that the board is bound to operate accordingly to rules of
procedural fairness and natural justice, employer counsel nonetheless underlines
that a matter has to be properly before the Board for them to be engaged.
Counsel returns to the decision of the OLRB in Hall v. Beauchamp for a clear
example of the principle that an administrative tribunal’s control over its own
procedure does not extend to the ability to accept an untimely complaint in the
face of statutory time lines. Counsel for the employer urges a finding that there is
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no case properly before the board that would trigger the obligations of procedural
fairness. Employer counsel distinguishes the Prassad decision, relied on by
complainant’s counsel, on the basis that it did not involve a statutory limitation
such as the one in issue here. Rather, it was a decision about an adjournment,
after the Immigration Appeal Board had taken undisputed jurisdiction of the
matter. Counsel argues that there is no conflict between Prassad and the case
law such as the OLRB’s decision in Hall and Beauchamp. Once a complaint is
within a Board’s jurisdiction, “in the door” so to speak, the Board’s control of its
own process is active, but not before. Further, the situation is not like that in the
cases cited on behalf of the complainant where there were competing pieces of
legislation in the mix.
[29] Turning to the complainant’s argument about estoppel, employer counsel argues
that the essential elements are not present. Counsel emphasizes that Mr.
Telford’s e-mail to the employer when he had learned of the death of his lawyer
did not ask for an extension of time. To the contrary, he asserts in his affidavit
that he thought that there were no applicable time lines. In those circumstances,
there could be no common assumption of fact to form the basis for an estoppel,
or any representation from the employer on which to base any understanding
that the employer was waiving the statutory time lines. Further, counsel submits
there is nothing in the complainant’s affidavit from which the Board could find that
he had relied on the employer’s response to affect the legal relationship between
the parties. Counsel emphasizes as well that factual situations where the
complainants were not aware of the time lines applicable to the PSGB, such as
Halsted and Berezowsky; have not been found to permit the Board to ignore
them.
[30] Counsel distinguishes the Ryan v. Moore and Cabot Insurance decision, cited in
Appendix B, referred to by complainant`s counsel, on the basis that the Court
does not say that there would be an estoppel in circumstances such as the one
here where the parties did not discuss the time lines. Employer counsel submits
that silence or inaction would be considered a representation if a legal duty
existed to inform the other party of something. Counsel underlines that the
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employer did not owe a legal duty to Mr. Telford to have advised him that he
risked missing the time lines while he sought a new lawyer.
[31] Employer counsel urges a decision consistent with the Board`s own
jurisprudence and that of the OLRB to the effect that, even in circumstances
where there is a sympathetic factor, Boards of arbitration and statutory tribunals
have found they could not extend the time limits in the face of mandatory
language.
***
[32] Prior to the current regulation, during the period when Regulation 977, set out in
the Appendix to this decision, was in effect, the Board had the discretionary
power under s. 54 of that Regulation to extend time limits, and exercised that
discretion in appropriate cases. What was considered appropriate depended on
the facts, including whether the delay was not too extensive, there were
reasonable grounds for the delay and/or no prejudice to the other party. This was
similar to the power provided in s. 48(16) of the Labour Relations Act (LRA),
which gives an arbitrator under a collective agreement the power to extend time
lines where there are reasonable grounds for the extension and the opposite
party will not be substantially prejudiced by the extension, unless the parties
agree that such power is not applicable. The situation changed when the current
regulation was put in place without the equivalent power.
[33] The Board has accepted in St. Amant and Ontario (Ministry of Community Safety
and Correctional Services), cited in Appendix B, that the current wording of the
regulation means that compliance with the time limits set out in the regulation is a
precondition to the Board’s assuming jurisdiction over a case. Further, the Board
found that it has no power to relieve against or extend those times limits, given
the removal of that power from the wording of the current regulation. This is
consistent with the case of Leisureworld, cited above, where despite the lack of
explicit language repealing a previous power to relieve against a time limit for
submissions to arbitration, the Court found that the removal of the wording
allowing it was equivalent to the repeal of the power.
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[34] In Burkholder, relied on by the employer, this Board considered the time limits set
out in Regulation 378/07, and wrote as follows at paras. 10 and 11:
There still remains the issue of whether the PSGB has any
authority to extend the time limits set out in section 8 of Regulation
378/07 in light of the complainant's claim that the delay was due to
a stress related illness. Even though the Board's statutory power to
extend time limits had been revoked in 1996, there are PSGB
decisions arising during the period from 1996 until Regulation
378/07 came into force where the Board exercised its discretion to
extend time limits. These cases, however, all dealt with the time
limits set out in former Regulation 977 and these time limits had
been clearly expressed in directory language. The language used
to prescribe time limits in the new Regulation 378/07, however, is
significantly different and leaves no doubt as to its mandatory
nature. This choice of mandatory language can lead to no other
conclusion than that compliance with these time limits is a
precondition to the PSGB assuming jurisdiction over a matter.
Given the mandatory nature of these time limits and the lack of any
express statutory authority to relieve against these mandatory time
limits, the Board must conclude that it has no power to alter the
jurisdictional consequences of a failure to comply with the 14 day
time limit to file the Form 1 Application. It is for this reason that this
complaint must be dismissed. This conclusion is in no way a
reflection on the merits of the complaint itself but merely a
determination that the Public Service Grievance Board, as a
tribunal created by statutory enactments, can only stay within the
limits of these enactments.
[35] This lack of power to relieve against the time limits means that the reasons for
not meeting the time lines, however reasonable or sympathetic, are not matters
that the Board can rely on to extend the time lines.
[36] Counsel for the complainant urges the Board to find that the restrictions in the
regulation are so problematic in the ways set out above, that they should not be
considered binding in the way that the Board has found them to be in its previous
decisions interpreting Regulation 378/07. Despite the accuracy of counsel’s
observations about what one could term a lack of user-friendliness of the wording
of the regulation, as well as the fact that it can work hardship in particular cases, I
do not find it appropriate to depart from the Board’s established jurisprudence.
The Board’s case law, in my view, has been faithful to what the regulation says,
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interpreted in light of Court decisions such as Leisureworld. As well, Courts at the
highest level, as demonstrated in the Supreme Court of Canada’s decision in
Ryan v. Moore and Cabot Insurance, have upheld the concept of limitation
periods prescribed by the legislature, albeit in that case, of the much longer
variety applicable in civil law suits.
[37] Further, consistency, short of rigidity, in tribunal decision making is highly
desirable, as affirmed by the Supreme Court of Canada, in IWA v. Consolidated-
Bathurst Packaging Ltd., [1990] 1 SCR 282, 1990 CanLII 132 (SCC). This
Board’s interpretation of the time limits in Regulation 378/07 has been articulated
in a consistent way whenever issues have been raised about them, and it is for
the regulatory process to change course if so advised.
[38] I have also considered the complainant’s argument that the doctrine of estoppel
should be applied. This is a rule of fairness which prevents one party from
enforcing its strict rights, where it has represented to the other party that it would
not do so, and the other party has relied to its detriment on that representation. I
do not find there to be any evidence of a representation in this case to the effect
that the employer would not rely on the statutory time lines. The courteous reply
of the employer’s representative to the distressing news of Mr. Eberhard’s death
does not deal with the issue. Further, although it is accurate to say that estoppel
can arise from silence or acquiescence in certain circumstances, I do not find this
case to be one of them. The communication by Mr. Telford that he was seeking
other counsel occurred at a time when he was still within the period of a timely
complaint. It did not ask for an extension of the time limits, or mention them at
all. The fact that the employer said nothing in the circumstances does not lead to
a clear inference of intention to not rely on the time limits or communication from
which the complainant could draw the conclusion that they would not. The
employer’s silence is at least as consistent with the idea that they had not been
raised at all.
[39] For similar reasons, I do not find that the employer has waived its rights to bring
this motion. To find waiver, there would have to be a communication, by action
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or acquiescence, of an intention to give up a right. I do not find the facts of this
case to be sufficiently clear to support the conclusion that the employer waived
its rights to rely on the applicable regulatory time lines.
[40] Therefore, the complaint is not eligible to go forward because it was filed late,
and the Board no longer has the authority to extend the time limits. It is therefore
not in a position to hear and determine the merits of Mr. Telford’s complaint, and
the above decision is in no way a comment on the issue of whether there was
just cause for his dismissal.
[41] In the circumstances, for the above-noted reasons, the complaint is dismissed.
Dated at Toronto, Ontario this 25th day of May 2016.
Kathleen G. O’Neil, Chair
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APPENDIX A
Excerpt from Regulation 378/07 under The Public Service of Ontario Act
Complaints Authorized by This Regulation
Complaint about dismissal for cause
2. (1) A person who is aggrieved by his or her dismissal for cause under
section 34 of the Act may file a complaint about the dismissal for cause with
the Public Service Grievance Board,
(a) if the person is eligible under sections 5 and 6 to file such a complaint;
(b) if the person gives notice in accordance with section 8 of his or her
proposal to file the complaint; and
(c) if the person complies with the filing requirements set out in section 10.
O. Reg. 378/07, s. 2 (1).
…
Filing a Complaint
Notice of proposal to file a complaint
8. (1) A person who proposes to file a complaint shall give notice of the
proposal to the following person or entity:
1. A complainant who, at the material time, worked in a ministry shall give the
notice to his or her deputy minister.
2. A complainant who, at the material time, worked in a Commission
public body shall give the notice to the chair of the Public Service
Commission. O. Reg. 378/07, s. 8 (1).
…
(4) The notice must be given within the following period:
1. For a complaint about dismissal for cause, within 14 days after the
complainant receives notice of the dismissal.
2. For a complaint about a disciplinary measure, within 14 days after the
complainant receives notice of the imposition of the disciplinary measure.
3. For a complaint about a working condition or a term of employment, within
14 days after the complainant becomes aware of the working condition or
term of employment giving rise to the complaint. O. Reg. 378/07, s. 8 (4).
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Period for dispute resolution
9. (1) A complainant is not entitled to file a complaint with the Public
Service Grievance Board until expiry of the period provided under this
section for dispute resolution. O. Reg. 378/07, s. 9 (1).
…
(4) If the complainant was required to give the chair of the Public
Service Commission notice of the proposal to make the complaint, and
if the chair or his or her delegate meets with the complainant within 30
days after the chair receives the notice, the period provided for dispute
resolution expires on the earlier of,
(a) the day that is 30 days after the meeting; or
(b) the day on which the chair gives written notice to the complainant of
his or her decision about the proposed complaint. O. Reg. 378/07, s. 9 (4).
(5) If the deputy minister or chair of the Public Service Commission, as the
case may be, or his or her delegate does not meet with the complainant
within 30 days after receiving the notice, the period provided for dispute
resolution expires 30 days after the notice was given to the deputy minister
or chair. O. Reg. 378/07, s. 9 (5).
Filing a complaint
10. (1) Within 14 days after the expiry of the period, if any, provided for
dispute resolution under section 9, the complainant may file the complaint
with the Public Service Grievance Board by delivering it to the chair of the
Board. O. Reg. 378/07, s. 10 (1).
(2) The complaint must set out the reasons for the complaint and must
include the notice of the proposal, if any, to make the complaint and such
other information and documents as the Board may specify. O. Reg. 378/07,
s. 10 (2).
(bolding added)
Excerpt from Regulation 977, under the Public Service Act, now superseded
37. A person who has received a notice under subsection 13(13) and who
believes he or she is being dismissed unjustly may, within twenty-one days of
the receipt of the notice, apply to the Board for a hearing, by delivering to the
Chair of the Board and application for a hearing including his or her
grievance.
…
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54. The Board or a Classification Rating committee may, of its own
motion,
(a) abridge the procedure set out in this Part and hear the grievance at
any time under section 48: or
(b) extend the time limits specified in this Part, RO 1980, Reg, 881, s. 61.
Excerpt from s. 48 of the Labour Relations Act:
s. 48
…
(16) Except where a collective agreement states that this subsection does
not apply, an arbitrator or arbitration board may extend the time for the
taking of any step in the grievance procedure under a collective
agreement, despite the expiration of the time, where the arbitrator or
arbitration board is satisfied that there are reasonable grounds for the
extension and that the opposite party will not be substantially prejudiced
by the extension. 1995, c. 1, Sched. A, s. 48 (16).
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APPENDIX “B”
Authorities relied on by the Employer
1. Public Service Act, Reg. 977, Part V – Grievance Procedure.
2. Public Service of Ontario Act, 2006, Ontario Reg. 378/07- Public Service
Grievance Board: Complaints and Hearings.
3. S.E.I.U., Local 204 v. Leisureworld Nursing Homes Ltd., 70 A.C.W.S.(3d) 281
[1997] O.J. No. 1469, 99 O.A.C. (Divisional Court), affirmed by the Court of
Appeal with brief reasons reported at [1997] O.J. No. 4815, 75 A.C.W.S. (3d) 854
(Ont. C. A.).
4. St. Amant (Complainant) v. The Crown in Right of Ontario (Ministry of
Community Safety and Correctional Services), PSGB No. P-2012-0601, January
31, 2013, 2013 CanLII 4673 (ON PSGB) (Carter).
5. Hall v. Beauchamp, 2010 CLB 2419.
6. Mike Lee et al and Jim Allen (Complainants) v. The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services), PSGB No. P-2010-
0702, P-2010-1055, July 21, 2011 (O’Neil).
7. Martin Ois (Complainant) v. The Crown in Right of Ontario (Ministry of
Community Safety and Correctional Services), PSGB No. P-2013-0884,
November 13, 2014 (O’Neil).
8. Hasted/Berezowsky (Complainants) v. The Crown in Right of Ontario (Ministry of
Community Safety and Correctional Services), PSGB No. P-2014-2665, January
18, 2016 (Nairn).
9. Donn Burkholder (Complainant) v. The Crown in Right of Ontario (Ministry of
Government Services), PSGB No. P.-2013-0846, November 8, 2013 (Carter).
Authorities relied on by the Complainant
10. Excerpt from Halsbury’s Laws of Canada – Administration Law (2013 Reissue),
Guy Régimbald, Matthew Estabrooks (Contributors); HAD – 4 Procedural
fairness and natural justice.
11. Prassad v.Canada (Minister of Employment and Immigration), [1989] 1 S.C.R. 560.
12. Ryan v. Moore and Cabot Insurance Company, 2005 S.C.C. 38.