HomeMy WebLinkAboutP-2023-01674.Gilkes.24-05-23 DecisionPublic Service
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PSGB# P-2023-01674
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Gilkes Complainant
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The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Thomas Kuttner, K.C. Vice Chair
FOR THE
COMPLAINANT
Andrew Camman
Spero Law
Counsel
FOR THE EMPLOYER Dimitrios Molos and Suneel Bahal
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING May 7, 2024
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Decision
[1] This is a Complaint originally filed on September 5, 2023 pursuant to subsection
4(1) of OReg 378/07 (“the Regulation”) under the Public Service of Ontario Act,
2006, SO 2006 c.35 Sch A (“the Act”). In it, the Complainant, Christian Gilkes, a
Sergeant at the Central East Correctional Centre, alleges that the Employer, by
letter dated August 16, 2023, dismissed him without just cause.
[2] The Employer brings a preliminary motion to have the Complaint dismissed on the
basis that the Board does not have jurisdiction to entertain the within Complaint
because it was filed during the dispute resolution period stipulated at subsections
9(1) & (5) of the Regulation. This decision addresses only that preliminary motion.
[3] The Parties filed an Agreed Statement of Facts (“the ASF”) and an attached Joint
Book of Documents (“the JBD”) for the sole purpose of the Employer’s preliminary
motion, in the following terms:
Agreed Statement of Facts
[4] The Complainant was dismissed with cause by way of letter dated August 16, 2023.
This letter is attached at Tab 1.
[5] By email dated August 21, 2023 at 5:33pm, the Complainant provided the Deputy
Solicitor General with notice of his proposal to file a complaint with the Board with
respect to the dismissal for cause on August 16, 2023 (the “Notice of Proposal”).
[6] The Parties recognize that the Notice of Proposal was filed within the timelines set
out in the Regulation.
[7] On August 22, the Employer replied to acknowledge receipt of the Complainant’s
Notice of Proposal.
[8] By email dated August 24, 2023 at 12:24pm, the Employer provided a response:
This correspondence serves to notify you that the Employer will not be
meeting with you to hear your notice of proposal to make a complaint.
Should you wish to file your complaint with the Public Service
Grievance Board, you are required to do so in accordance with the
timelines set out in Regulation 378/07 of the Public Service of Ontario
Act, 2006. Here is a link to the regulation for your reference: O. Reg.
378/07: PUBLIC SERVICE GRIEVANCE BOARD: COMPLAINTS
AND HEARINGS (ontario.ca)
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The Employer reserves the right to raise any and all preliminary
objections regarding your complaint.
In other words, the Employer informed the Complainant that the Regulation
establishes timelines for the proper filing of a complaint, and provided notice that it
would bring preliminary objections based on a failure to comply with the timelines.
This email is attached at Tab 2.
[9] Because the Notice of Proposal was provided to the Deputy Solicitor General on
August 21, 2023, pursuant to subsection 9(5) of the Regulation, the dispute
resolution period commenced on August 21, 2023 and ended on September 20
2023.
[10] By email dated September 5, 2023 at 9:45pm, the Complainant filed the Complaint
dated September 5, 2023.
Please accept my completed form 1 application and appendices for an
incident that occurred on June 13th, 2023.
This email and its attachments are attached at Tab 3. For reasons unknown to the
Employer and the Complainant, contrary to its usual practice, the Board did not
process this filing, or provide the Employer with an acknowledgement letter and the
Complainant’s Form 1.
[11] The Complainant’s Form 1 identified his legal representative as Mr. Andrew
Camman of Spero Law, and provided his counsel’s address, email, and telephone
number. The Form 1 is dated Tuesday, September 5, 2023.
[12] On September 6, 2023 at 9:00am, the Board’s Registrar replied to the Complainant,
copying Ms. Sharifi Kadri (Litigation Law Clerk at Spero Law). The email begins with
the following paragraph:
Thank you for submitting your PSGB Form 1 Application dated
September 5, 2023. In reviewing your application, I note that the Notice
of Proposal to your Deputy Minister is not attached and is required as
part of the application.
The Employer was not copied on this correspondence, or given any notice of it.
Moreover, the Board’s Registrar did not instruct the Complainant to copy the
Employer on his correspondence with the Board. This email is attached at Tab 4.
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[13] On September 6, 2023 at 10:17am, the Complainant replied to the Registrar’s email,
copying Ms. Kadri. The Employer was not copied on this correspondence, or given
any notice of it. This email and its attachments are attached at Tab 5.
[14] On September 6, 2023 at 12:37pm, the Registrar replied again, copying Ms. Kadri.
The Employer was not copied on this correspondence, or given any notice of it. The
email begins and ends with the following paragraphs:
Thank you for providing a copy of your Notice of Proposal dated
August 21, 2023. It appears that the PSGB Form 1 Application has
been submitted to the Board prematurely, dated September 5th, 2023.
[...]
Based on the above information, I invite you to reconsider the
applicability of those sections of the Regulation and whether you wish
to file this application now.
This email and its attachments are attached at Tab 6.
[15] On September 12, 2023 at 9:45am, surprised that the Board had not yet processed
his Complaint, the Complainant wrote to the Board once again:
I resent my grievance on September 6th as per the instructions given
but have yet to hear a reply to confirm that it has been received. Can
you please tell me the state of my grievance please? Thank you.
This email is attached at Tab 7. The Employer was not copied on this email.
[16] At 9:57am, the Board’s Registrar sent a response to the Complainant by replying to
the email dated September 6, 2023 at 12:37pm, and copying the Complainant’s
counsel and Ms. Kadri.
If you could please review my email dated September 6, 2023 (below),
at the end of the email you were invited to reconsider the applicability
of the sections of the Regulation and whether you wish to file this
application now. Please advise.
This email is attached at Tab 8. The Employer was not copied on this
correspondence, or provided with any notice of it.
[17] On or around September 13 or 14, 2023, the Complainant had a telephone
conversation with the Board’s Registrar. According to the Complainant, the
Registrar provided him with a “definitive date” for a timely filing, and based on this
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advice, the Grievor filed at that time. The Employer has no direct knowledge of this
conversation or what was said. The Employer was not notified of this call or its
purpose, invited to participate in it, or given an opportunity to take a position or
provide argument on any substantive or procedural issue.
[18] On September 22, 2023 at 10:59am, the Complainant filed his Complaint with the
Board for the third time, copying his Counsel, Ms. Kadri, and the Board’s Registrar.
In this email, the Complainant expressed his gratitude to the Registrar:
I would like to thank the Public Service Grievance Board, specifically
Ms. Caillier for clarifying the submitting dates and to apologize for
submitting too early. I understand that this was an error on my part and
I am now submitting my grievance at the appropriate time.
The Employer was not copied on this email. This email and its attachments are
attached at Tab 9.
[19] On September 25, 2023 at 10:06pm, the Registrar sent an acknowledgement letter
and the Complainant’s Form 1 to the Employer. This email and the attachments are
attached at Tab 10. The acknowledgement letter begins with the following sentence:
Notice is hereby given that the Public Service Grievance Board is in
receipt of the above captioned grievance, dated September 22, 2023,
and received on September 22, 2023, a copy of which is enclosed.
But the Complainant’s Form 1 was dated September 5, 2023, and the Board
received the Complainant’s Form 1 by email dated September 5, 2023.
[20] By email dated December 1, 2023 at 10:35am, Counsel for the Employer inquired
into the possibility of typographical errors in the Board’s acknowledgement letter:
I’m counsel on this matter for the Employer. I’m working on my reply
in preparation for the case management call, and I’m wondering if
there’s a typo in the Board’s acknowledgement letter. According to the
acknowledgement letter, the complaint is dated September 22, but the
two copies of the Form 1 attached to your email are both dated
September 5. Would you please advise whether the acknowledgement
letter is accurate? Also, for the Book of Documents, would you please
send me the email where the Complainant filed the Form 1?
This email is attached at Tab 11.
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[21] On December 4, 2023 at 10:14am, the Board’s Registrar replied to Employer
Counsel’s email, also copying the Complainant’s Counsel:
In response to your enquiry of December 1, 2023, Mr. Gilkes initially
filed his application with the Board on September 5, 2023, and the
Form 1 was dated September 5. I responded advising him that his
application appeared to be premature and asking whether he wished
to proceed with it at that time. That email exchange is attached. I was
advised by Mr. Gilkes either on September 13th or 14th, by telephone,
that he did not wish to proceed with the initial application at that time.
Mr. Gilkes then resubmitted his application on September 22, 2023.
His email doing so is attached. The application was therefore
processed as having been submitted on that date, however Mr. Gilkes
did not change the date that he signed the Form 1.
The email is attached at Tab 12, and attached to it were the emails found at Tabs 3
to 9.
[22] In its Form 2, the Employer took the position that the Board lacks jurisdiction to hear
the Complaint because it was filed prematurely during the legislated dispute
resolution period.
[23] The Complainant accepts that the filings on September 5, 2023 and September 6,
2023 were premature.
The Employer’s Submissions
[24] The Form 1 application dated September 5, 2023, lacking the Notice of Proposal to
the Deputy Minister as required, and the same Form 1 submitted to the Board on
September 6, 2023 with the Notice of Proposal attached, were filed prematurely
during the dispute resolution period as stipulated at Subsections 9(1) & (5) of the
Regulation. The premature filing of the Complaint deprives the Board of jurisdiction
to entertain it.
[25] The Form 1 filing of September 22, 2023 was improper and irremediably faulty. The
underlying Complaint was not amended and included Appendix A, Appendix B and
the Notice of Proposal. The Board Rules do not permit the filing of the same
materials on a different date. The Board lacks jurisdiction to entertain the Complaint
as filed on September 22, 2023.
[26] Moreover, the third filing of the Complaint on September 22, 2023 was done so on
the ex parte legal advice of the Board Registrar. But for that interference of the
Registrar, there would have been no filing of the Complaint on September 22, 2023.
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[27] Subsection 23 (1) of the Act stipulates at paragraph 1 that subject to paragraph 2
the Statutory Powers Procedure Act and any rules made under that Act by the Board
apply to proceedings before the Board. Paragraph 2 provides that on the coming
into force of a regulation made under subsection (2) establishing procedural rules
for proceedings before the Board, the Statutory Powers Procedure Act and any rules
made under that Act cease to apply to proceedings before the Board to the extent
that that Act and any rules made under it conflict with the regulation. Regulation
378(7) was promulgated in 2006.
[28] The Board caselaw holds that the timelines stipulated in the Regulation are
substantial, not procedural and cannot be waived. The Board Rules stipulate at
section 1.F that “Filing” means the effective delivery of documents to the Registrar
of the Board. Rule 11 provides that the timelines stipulated by the Regulation are
triggered by the filing of the Complaint. Pursuant to Rule 14, the Board is to compile
a record of the proceedings before it, and Rule 15 provides for dismissal of the
Complaint without a hearing where it fails to make out a case for the orders or
remedies requested.
[29] The Rules provide in mandatory language that the Board process a Complaint when
filed. Upon acknowledging receipt of the Complaint on September 6, 2023 the
Board ought to have processed it. There is no legal authority allowing for the Board
not to process a Complaint when filed.
[30] It is only by e-mail dated September 25, 2023, that the Registrar acknowledged to
the Employer by letter addressed to the Deputy Minister that it was in receipt of a
Complaint dated and received on September 22, 2023. That acknowledgement
letter was misleading The Board did indirectly what it could not do directly, treating
the Complaint as if filed on a later date than it had been filed.
[31] The Complaint was neither amended in accordance with Board Rule 8, nor
withdrawn by his telephone conversation with the Registrar. In any event, upon
withdrawal, a Complainant cannot submit the same Complaint and materials on a
subsequent Complaint as was done here
[32] The correspondence and telephone conversation which the Registrar had with the
Complainant was ex parte, hence prejudicial to the Employer. Arguably, this
conduct raises a reasonable apprehension of bias on the part of the Board, depriving
it of jurisdiction to entertain the Complaint on the merits.
[33] In support, Counsel referenced the following jurisprudence:
Hamilton v Ontario (Community Safety and Correctional Services), 2019
CanLII 42439 (ON PSGB); LaForest v Ontario (Solicitor General), 2020
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CanLII 10543 (On PSGB); Morris et al v Ontario (Community Safety and
Correctional Services), 2018 CanLII 109220 (ON PSGB); Drakos v
Ontario (Solicitor General), 2023 CanLII 102931 (ON PSGB); St. Amant
v Ontario Ministry of Community Safety and Correctional Services), 2013
CanLII 4673 (ON PSGB); Bourgeault v Ontario (Community Safety and
Correctional Services),2013 CanLII 84294 (ON PSGB); Gauvin v Ontario
(Community Safety and Correctional Services); 2017 CanLII 89956 (ON
PSGB); Ihasz v Ontario (Finance) 2015 CanLII 89901 (ON PSGB);
Hasted v Ontario (Solicitor General), 2019 CanLII 78782 (ON PSGB);
Rabaey v Ontario (Children, Community and Social Services),2024
CanLII 16515 (ON PSGB); Trillium v Cassels Brock & Blackwell et al,
2013 ONSC 1789; Hunt v The Owners, Strata Plan LMS 2556, 2018
BCCA 159); 2539943 Ontario Inc v Addiction Recovery Network Inc.,
2020 CanLII 57707 (ON LRB); Taucar v University of Western Ontario,
2015 HRTO 515.
The Complainant’s Submissions
[34] Counsel submits that by its submissions, the Employer is obfuscating the purpose
of the Act and of the Board. It is offensive to suggest that what happened to the
Employer has brought the administration of justice into disrepute. To the contrary,
were the Complainant to lose his right to a hearing before the Board, the
administration of justice would be brought into disrepute.
[35] To suggest that the Complainant will lose his right to a hearing because an
administrative clerk provided perfunctory advice to him to ensure the proper filing of
the Complaint, and that the Employer has been prejudiced thereby, is absolutely
wrong. The timelines set out in the Regulation are confusing, and the Employer is
implying that there is no possibility to correct a mistake in applying them. The
September 22, 2023 filing is entirely proper.
[36] The general rules of interpretation found in the Legislation Act, 2006, SO 2006, c.21,
Sch F, stipulate at section 64(1):
An Act shall be interpreted as being remedial and shall be given such
fair, large and liberal interpretation as best ensures the attainment of
its objects.
[37] Once he received assistance from an administrative clerk to exercise his narrow
rights, the Complainant’s filing on September 22nd fell within the window set out in
the Regulation for filing his Complaint. There is no provision in the Regulation that
the Form 1 Notice of Complaint be dated within that window; rather it must be filed
within the 14-day window.
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[38] The Complainant has a right to file a Complaint under the legislation, and the
draconian approach the Employer takes, relying on the confusion within the
legislation, deprives the Complainant of the right to have his Complaint heard by the
Board. There is no caselaw that shows that this right of the Complainant should be
taken away.
[39] The Employer’s preliminary motion should be dismissed.
The Employer’s Reply
[40] The only issue to be determined is whether the Board has jurisdiction to entertain
this matter. The September 5th filing was improper because premature. Therefore,
the Board has no jurisdiction to proceed. The Complainant has a right to a hearing
before the Board only if his Complaint was properly filed.
[41] The right of the Employer to a fair hearing has been lost due to the conduct of the
Board, which raises a reasonable apprehension of bias. But for the ex parte
communication of the Registrar, there would be no matter to be heard today, for the
Board has lost jurisdiction.
[42] To correct his mistake of September 5th the Complainant ought to have sought
leave of the Board to withdraw his Complaint and refile it properly, but he did not do
so. It is relevant that the Complainant had legal representation at this time.
Analysis and Decision.
[43] At issue here is whether the Board has jurisdiction to entertain this Complaint on the
merits. I address the issue based on the agreed Statement of Facts, the
submissions of the parties, and the caselaw cited by the Employer. By way of
preliminary objection, the Employer submits that the Complaint, dated September
5, 2023 was prematurely filed on that date or the day following, September 6th. The
provisions of the Regulation here engaged are subsections 9(1) & (5) and 10(1) &
(2). These stipulate:
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.
…
9(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.
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10(1). Within 14 days after the expiry 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.
10(2). The complainant 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.
[44] The timelines stipulated in the Regulation for the filing of a Complaint have been
held by the Board to be mandatory, the Board having no jurisdiction to entertain a
Complaint on the merits where they are not complied with by a Complainant. In Re
Hamilton supra, the Board wrote:
[2] The Board has consistently held that the time limits in Regulation
378/07 are mandatory. If they are not met, the Board is deprived of
jurisdiction to hear the complaint. The Board has also consistently held
that it does not have the discretion to relieve against these time limits.
…
[3] the parties’ disagreement about whether the complaint was filed
within the time limits required by the regulations is a mixed question of
fact and law.
…
[45] In Re Hamilton, the Complaint was filed three days before the close of the dispute
resolution period. It was dismissed and the Board did not proceed to a hearing on
the merits. To the same effect, see Re Laforest supra, where the Complaint was
filed nine days before the close of the dispute resolution period; Re Morris supra,
where the Complaint was filed two days before the close of the dispute resolution
period; Re Drakos supra, where the Complaint was filed one day before the close
of the dispute resolution period; and Re Gauvin supra, where the Complaint was
filed two days before the close of the dispute resolution period;
[46] Here, the Notice of Proposal was sent to the Deputy Minister on August 21, 2023.
Pursuant to subsection 9(5) of the Regulation, the dispute resolution period
commenced on that date and expired on September 20, 2023, and pursuant to
subsection 10(1) of the Regulation, the fourteen day “window” of opportunity to file
the Complaint commenced on the latter date. Given that timeline, whether the
Complaint filed with the Board on September 22, 2023 was timely filed depends on
the effect of the documents submitted by the Complainant on September 5 and/or
September 6, 2023.
[47] The Employer submits that the Complaint was filed prematurely on September 5th
and/or September 6th. We can deal with the earlier date summarily. The
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Complainant failed to attach his Notice of Proposal to his September 5th filing which
was forwarded to the Board at 9:45 pm. By email dated September 6th at 8:59am,
the Registrar advised the Complainant that the application did not include the Notice
of Proposal, and suggested that he review the Board FAQs1, Rules and Practice
Notes, providing the links to them, the important timelines being highlighted. At
10:17am on September 6th the Complainant emailed the Board with the same Form
1 application together with Appendices and including the Notice of Proposal, and
thanked the Registrar “for your assistance in clarifying this issue”.
[48] Subsection 10(2) of the Regulation requires the Notice of Proposal to be included
with the Complaint. As it was not, the September 5th submission does not meet the
definition of “filing” in the definitional section 1 of the Board Rules, as it was not an
“effective delivery of documents to the Registrar of the Board.” (emphasis added).
This leaves for consideration the documents submitted on September 6th filing and
September 22nd.
[49] As noted above, on September 6, 2023, at 10:17 am, the Complainant submitted
the same Form 1 with appendices “A” and “B” together with the Notice of Proposal.
However, the Registrar did not process the application at that time. Rather, she
emailed the Complainant at 12:28pm, that “ it appears that the PSGB Form 1
Application has been submitted to the Board prematurely”. Once again she
suggested that the Complainant review the Board FAQs, Rules and Practice Notes,
providing links to them, and highlighting the important timelines. She concluded the
email as follows:
… Based on the above information, I invite you to reconsider the
applicability of those sections of the Regulation and whether you wish
to file this application now.
[50] On September 12, 2024 at 9:44 am, the Complainant emailed the Registrar to
advise that he had not yet received confirmation of receipt of the application and
inquiring of the state of his grievance. The Registrar replied at 9:57am suggesting
that the Complainant review her e-mail of September 6th and noting:
At the end of the email, you were invited to consider the applicability
of the sections of the Regulation and whether you wish to file this
application now. Please advise.
[51] On September 13 or 14, 2023, the Complainant had a telephone conversation with
the Board’s Registrar. According to the Complainant, the Registrar provided him
1. FAQs are a series of questions and answers published by the Board on its website to assist a Complainant to
navigate a complex set of legal procedures and timelines contained in the Regulation.
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with a “definitive date” for a timely filing. The Registrar states that during the phone
call, the Complainant told her that he did not want to proceed with the initial
application at that time. The Complainant later submitted the same Form 1 with
Appendices at 11:00am on September 22, 2023 well within the “window” for timely
filing stipulated at subsection 10(1) of the Regulation. In doing so he wrote:
I would like to thank the Public Service Grievance Board, specifically
Ms. Caillier for clarifying the submitting dates and to apologize for
submitting too early. I understand that this was an error on my part and
I am now submitting my grievance at the appropriate time.
In effect, given the Registrar’s invitations of September 6th and 12th noted above, I
find that the Complainant had withdrawn the application he had submitted on
September 6, 2023 in his phone call with the Registrar, which he then confirmed by
the filing of September 22nd.
[52] The Employer was not copied on the September 6th and 12th email correspondence
between the Registrar and the Complainant, nor was it privy to the telephone
conversation between them of September 13th or 14th. The office of Counsel for
the Complainant was copied on the emails.
[53] The Board processed the application filed on September 22nd in accordance with
its usual practice. By letter dated September 25, 2023, addressed to the Deputy
Minister, and copied to Treasury Board Secretariat (“TBS”), the Registrar
acknowledged receipt of the Form 1 application as follows:
Notice is hereby given that the Public Service Grievance Board is in
receipt of the above captioned grievance, dated September 22, 2023,
and received on September 22, 2023, a copy of which is enclosed.
Please complete the attached "Form 2" and return it to the Public
Service Grievance Board no later than 60 days of receipt of this notice.
[54] By e-mail dated December 1, 2023, Employer Counsel wrote to the Registrar as
follows:
I’m counsel on this matter for the Employer. I’m working on my reply
in preparation for the case management call, and I’m wondering if
there’s a typo in the Board’s acknowledgement letter. According to the
acknowledgement letter, the complaint is dated September 22, but the
two copies of the Form 1 attached to your email are both dated
September 5. Would you please advise whether the acknowledgement
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letter is accurate? Also, for the Book of Documents, would you please
send me the email where the Complainant filed the Form 1?
[55] The Registrar responded to Employer Counsel by email dated December 4, 2023,
copying Complainant’s Counsel:
In response to your enquiry of December 1, 2023, Mr. Gilkes initially
filed his application with the Board on September 5, 2023, and the
Form 1 was dated September 5. I responded advising him that his
application appeared to be premature and asking whether he wished
to proceed with it at that time. That email exchange is attached. I was
advised by Mr. Gilkes either on September 13th or 14th, by telephone,
that he did not wish to proceed with the initial application at that time.
Mr. Gilkes then resubmitted his application on September 22, 2023.
His email doing so is attached. The application was therefore
processed as having been submitted on that date, however Mr. Gilkes
did not change the date that he signed the Form 1.
[56] From the foregoing, I conclude that the Form 1 application submitted to the Board
on September 6th was, as that submitted on September 5th , treated by the Registrar
as not being effectively filed, inasmuch as it was premature, falling within the 30 day
period provided for dispute resolution under Regulation subsection 9(5). Therefore,
it was not immediately processed by the Board but was withdrawn by the
Complainant before any fresh steps had been taken.
[57] This leaves for consideration the question whether the Form 1 application submitted
to the Board on September 22, 2023, was effectively filed. That the Form 1 was
dated September 5, 2023 is not determinative of when it was effectively filed within
the meaning of the Board Rules. The Employer submits that the September 22nd
application is irremediably faulty by reason of the ex parte correspondence and
telephone conversation between the Registrar and the Complainant on September
6th, 12th and 13th /14th. Counsel references the decision of the British Columbia Court
of Appeal in Hunt v The Owners, Strata Plan supra in support. There, the Court
addressed the issue as follows:
[85] What would an informed person, viewing the matter realistically and
practically, and having thought the matter through, conclude about the impartiality
of the arbitrators, in light of the ex parte communications? Would one think it is
more likely than not that the decision-maker or decision-makers, whether
consciously or unconsciously, would not decide fairly?
[86] It is well-accepted in the context of judicial proceedings that a judge
ought not to discuss any part of an ongoing case with only one party to the
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dispute, or a witness. If a judge were to discuss a case with only one party, even
in good faith, this could be sufficient to create a reasonable apprehension of bias.
[87] As explained by Dickson J. in Kane v. University of British Columbia,
1980 CanLII 10 (SCC), [1980] 1 S.C.R. 1105 at 1113–1114:
It is a cardinal principle of our law that, unless expressly or by
necessary implication, empowered to act ex parte, an appellate
authority must not hold private interviews with witnesses … or, a
fortiori, hear evidence in the absence of a party whose conduct is
impugned and under scrutiny. Such party must… “. . . know the case
which is made against him. He must know what evidence has been
given and what statements have been made affecting him: and then
he must be given a fair opportunity to correct or contradict them. .
. Whoever is to adjudicate must not hear evidence or receive
representations from one side behind the back of the other.”…
[Emphasis added; citations omitted.]
[88] A number of cases have considered the problem of a decision-maker
communicating privately with only one party to the dispute.
[58] The key to Hunt v The Owners, Strata Plan and those cited by it, is that it is decision-
makers who are foreclosed from communicating ex parte with one or the other of
the parties or their counsel during proceedings before them. But that is not the case
here. The correspondence and telephone conversation at issue were between the
administrative staff of the Board at a preliminary stage of the process, long before
the Complaint was taken up on the merits by a decision-maker i.e. the Chair or a
Vice-Chair of the Board. In these circumstances, I find that the ex parte
correspondence and telephone conversation were not fatal to the Complainant’s
case, nor can they be said to have raised a reasonable apprehension of bias.
Furthermore, there is no evidence that these communications were prejudicial to the
Employer which had the benefit of the full period for dispute resolution and, in accord
with the ordinary Board process, will have a full opportunity to participate in the
hearing on the merits of the case.
[59] That being said, there are limits to what may be discussed ex parte. The caselaw
makes it clear that even the administrative staff of a court or an administrative
tribunal are precluded from offering legal advice to a party filing an application before
it. In Trillium v Cassels Brock & Blackwell supra, the Court distinguished legal
advice from legal information as follows:
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How do I decide whether documents relating to CADA’s
communications to and from its legal counsel are privileged? I can do
no better than to adopt the approach that was put forward by both
CADA and CBB. One must differentiate between legal information and
legal advice. Legal information consists of providing answers
regarding the law generally, the options available, and the relevant
legal procedures that might pertain.[7] For example, information
provided by CBB to CADA about the federal bankruptcy process and
the CCAA and how it would affect the dealers is legal information, not
legal advice.
[12] Legal advice, on the other hand, is advice that is given with
respect to the client’s legal rights and duties and is given on the
understanding that it may well be followed.[8] It depends on the
individual circumstances of the recipient[9] and consists of a much
more personalized opinion on the way the law would apply in a
particular case or about the particular decision that should be made in
the circumstances.[10] Legal advice involves the interpretation of legal
principles “to guide future conduct or to assess past conduct.”[11] In
short, legal advice is particularized advice that is directed to the client’s
legal rights or duties and in essence says “here is what I think you
should do” as opposed to “here is some information about the CCAA
and the federal bankruptcy process.”[citations omitted].
[60] Measured against that test how ought one to characterize the correspondence
between the Registrar and the Complainant of September 6th and 12th and their
telephone conversation of September 13th/14th ? On both September 6th and 12th
the Registrar suggested that the Complainant review the Board FAQs, Rules and
Practice Notes, providing links to them, and highlighting the important timelines. On
both dates she concluded the email correspondence by inviting the Complainant to
reconsider the sections of the Regulation highlighted and whether he wished to file
the application at that time. As noted above at paragraph 39 it is clear that the
Registrar treated the September 6th application as not being effectively filed as it
was “submitted to the Board prematurely.” The language used is telling— the
application was “submitted” not “filed”. I have no difficulty concluding that the
Registrar’s correspondence of September 6th and 12th was legal information, not
legal advice.
[61] But what of the telephone conversation of September 13th/14th between the
Registrar and the Complainant? The agreed Statement of Facts between the Parties
states “According to the Complainant, the Registrar provided him with a “definitive
date” for a timely filing, and based on this advice, the Grievor filed at that time.” Yet
in evidence, we have the Complainant’s statement to the Board on submitting the
application that “I would like to thank the Public Service Grievance Board,
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specifically Ms. Caillier for clarifying the submitting dates”. [emphasis added]. And
in her response to Employer Counsel of December 25, 2023, the Registrar writes: “
I was advised by Mr. Gilkes either on September 13th or 14th, by telephone, that he
did not wish to proceed with the initial application at that time.”
[62] The issue is somewhat murky. However, on reviewing in its entirety the evidence
noted at the foregoing paragraph, I have concluded, on the balance of probabilities,
that in the telephone conversation of September 13th/14th, the Registrar provided
the Complainant with legal information, not legal advice. She did not give
“particularized advice that is directed to the Complainant’s legal rights or duties” or
an “opinion on the way the law would apply in a particular case or about the decision
which should be made” i.e. legal advice; rather she provided legal information
“regarding the law generally, the options available, and the relevant legal
procedures that might pertain”.
[63] For all of the foregoing reasons, the Employer’s preliminary motion that the Board
lacks jurisdiction to entertain this case on the merits is dismissed.
Dated at Toronto, Ontario this 23rd day of May 2024.
“Thomas Kuttner”
Thomas Kuttner, K.C., Vice-Chair