HomeMy WebLinkAbout1982-0530.Millar and MacPhail.83-03-23IN THE MATTER OF AN ARBITRATION
.Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE-SETTLEMENT BOARD
Between:
Before:
For the Grievors:
For the Employer:
Hearing: January lOth, 1983
OPSEU (Brian Miller and Clair MacPhail)
- And -
Grievors
The Crown in Right of Ontario
(Ministry of Correctional
Services) Employer
R.L. Verity, Q.C. Vice Chairman
L. Robbins Member
W.A. Lobraico Member
G.A. Richards. Grievance Officer Ontario Public Service Employees Union
J.F. Benedict
Manager, Staff Relations Ministry of Correctional Services
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DECISION
In two separate Grievances, Brian Miller and
Clair MacPhail allege "unjust termination" as Correctional
Officers 1 at the Cornwall Jail. The issue in each Grievance
is identical and for that reason the Parties agreed that both
Grievances would proceed together at the Hearing. The Grievors
seek reinstatement by way of settlement.
The Cornwall Jail is a maximum security institution
responsible for the custody of approximately 25 inmates. The
staff at the Jail numbers 21 persons and in addition 7 part-time
Correctional Officers 1 who are colloquially referred to as
"casuals". These latter Correctional Officers are Public
Servants who are members of the unclassified service and are
governed by Article 3 of the Collective Agreement. Members of
the unclassified service are hired pursuant to fixed term
contracts.
At the Cornwall Jail, casuals employed as Correctional
Officers are employed pursuant to a one year contract. The
Grievor Brian Miller was first employed at the Cornwall Jail
'on October 24th, 1977 (Exhibit 8). Clair MacPhail was first
employed at the same institution on November 20th, 1978 (Exhibit
10). The date of both Grievor's renewal contracts was April
lst, 1982. Similarly, the expiry date of those contracts is
identical, namely Narch 31st, 1983.
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Each of the Grievor's individual contracts contain
the following wording:
"Working Conditions & Benefits: as per
Collective Agreement
Other Terms & Conditions
Normal hours of work not to exceed
* 24 per week
. Services may be terminated on one (1)
week's notice by e
Both Grievors received
August 12th, 1982. In Brian Mil 1'
ither party....."
letters
er's le
of termination
tter of termination
(Exhibit 3) Cornwall Jail Superintendent Richard Dagenais
stated that a review of Mr. Miller's work record from January,
1982 to the end of July demonstrated that the Grievor worked
an average ,of only one shift per month. In Clair MacPhail's
letter of termination (Exhibit 6).the Superintendent alleged
that Mr. MacPhail had worked an average of only two shifts per
dated
month in 1982
At t he Hearing, the Superintendent stated that the
unavailabili.ty of both Grievor's for work was the sole reason
for their termination. Mr. Dagenais testified that his policy
for the employment of casual staff was simply that he expected
casuals to be reasonably available for work when required.
He admitted that notice to casuals for shift work would frequently
be short notice varying in many instances from one hour to fifteen
minutes. He also testified that he had no direct involvement in
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the employment of casuals which in turn was the responsibility
of the shift supervisors. However, Mr. Dagenais had instructed
his shift supervisors to allocate casual employment equitably.
The Superintendent stated that he had never warned either Grievor
that dismissal could be the end result when casuals were deemed
to be unavailable for work.
Both Grievors testified that neither had been warned
by anyone at the Jail that availability for work was a problem.
In particular, Mr. MacPhail testified that there was "no real
system" for the employment of casuals. Mr. Miller testified
that favoritism by shift supervisors in the employment of casuals
was a problem. He also testified that the number of calls that
he personally received in 1982 declined sharply from calls received
in previous years.
On behalf of the Employer, Mr. Benedict argued that the
Grievors' services were terminated for non-disciplinary reasons
and accordingly the Board lacked jurisdiction in the matter.
Further, he argued that termination was affected in accordance
with the provisions of Article 3.11 of the Collective Agreement
and there had been no violation of the Collective Agreement. Mr.
Benedict argued that both Grievors were.well aware of the terms
and conditions of employment contained in their individual contracts
and in the Collective Agreement.
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I
On behalf of the Grievors, Mr. Richards alleged
that both Messrs. Miller and MacPhail were dismissed in a
disciplinary sense and had been given no warning to enable
either to correct any perceived deficiency. He argued
forcefully that no policy was in force at the Cornwall Jail
for the employm'ent of casuals to guide casual employees on
the issue of availability for work.
The following Articles of the Parties' Collective
Agreement are relevant:
"3.11 Employment may be terminated by the
Employer at any time with one (1) week's
notice or pay in lieu thereof."
"3.14 The following Articles shall also apply
to seasonal or part-time employees;
Articles 1, 9, 11, 12, 15, 16, 17, 21,
22, 23, 25, 27, 32, 36 and 57."
In a determination of the issue, we adopt the
rationale of Professor Prichard in Boucher and Trumbley and
Ministry of Correctional Services, 218/78 at page 9:
"In our view, the Board's jurisdiction extends
at a minimum to characterizing any particular
set of facts surrounding the ending of an
unclassified employee's employment relationship
as a dismissal for cause within the meaning of
section 17(2)(c) (Now 18(2)(c)) or a 'termination'
within the meaning of Article 3.3 of the
collective agreement.
To decide otherwise would be to abdicate our
statutory responsibilities under section 17
and 18 of the Crown Employees Collective
Bargaining. Act which charges us with the duty
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-
to decide a claim by an employee that he
or she has been dismissed without just
cause. Implicit in that duty is a duty
to delineate our jurisdiction by deter-
mining in each case brought before us
whether or not the facts amount to a
dismissal or not. The Ministry may not
deprive an employee of his section 17(2)(c)
rights by calling a disciplinary dismissal
a termination within the meaning of Article
3.3. Similarly, an employee cannot gain
greater rights by calling a bona fide
termination a disciplinary dismissal in
order to come within the terms of section
17(2)(c). Rather, after hearing the
evidence of all the circumstances surround-
ing the severing of the employment relationship
this Board must decide uoon the orouer
characterization
cases characteri Z
employee will be
offered by Artic 18
characterized as
must be prepared
of section 17(Z)
of each'case. ior'those
ed as a termination, the
limited to the protection
e 3.3. For those cases,
dismissals, the Ministry
to meet the requirements
. . ..we have determined that our juri S
under Section 17 and 18 of the Crown
Collective Bargaining Act extends at
hear and then characterize the facts
the severing of the employment relati
a member of the unclassified service
a termination within the meaning of A
diction
Employees
a minimum to
surrounding
onship of
as either
rticle 3.3
of the collective agreement or a dismissal for
cause within the meaning of section 17(2)(c)
of the statute. If the latter characterization
is applied, our jurisdiction will then extend
to determining the merits of the claim that
the dismissal was without just cause. If the
former applies, our jurisdiction will be at
an end assuming the requirements of Article
3.3 were met."
In our view, the instant Grievance can best be
characterized as a dismissal which we find has been without
just cause.
. . .’
.’
I
The sol
Richard Dagenais.
e wi tness for the Employer was Superintendent
Cl early, his testimony regarding the Grievor'
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availability for work was essentially hearsay evidence, and
accordingly has litele cogency in law., See Re Girvin et al and
Consumers' Gas Company (1973), 1 O.R. (2d) 421 (Holland J);
and R. vs Barber et al., Ex p. Warehousemen and Miscellaneous
Drivers' Union, Local 419 [1968] 2 O.R. 245, 68 O.L.R. (2d)
682 Jessup. J.A.
On the ev
been devised at the
on an equitable bas
;
dence,
Cornwa
S.
it is clear that no system has yet
11 Jail for the employment of casua 1s
In addressing the issue of the appropriate remedy,
we refer again to the Boucher Award of Professor Prichard,.
cited above at pages 18 and 19:
. ..we are confronted with the bold language of
Article 3.3 of the collective agreement which,
as we have interpreted it, provides for only
one week's notice or one week's pay in lieu of
notice when a casual employee .is terminated.
Whatever our personal views as to the substan-
tive adequacy of such a provision as a form of
job protection, particularly as it applies to an
employee who has in effect served for seven years,
it would, in our view, be inappropriate for'us to
disregard the parties' intenti.ons as expressed in
Article 3.3 in considering the appropriate remedy.
On the face of the collective agreement, the parties
have turned their minds to the degree of job
protection to be afforded casual employees and
have reached agreement on the question. The term
'termination' is given no limit in Article 3.3;
it is not limited to situations in which there is
no longer work to be performed. In normal usage
it should be taken as including a dismissal and
there is nothing in the collective agreement to
oust the normal inter.pretation. Thus, on its face,
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Article 3.3 specifies the scope of protection to
be accorded casual employees. When read with
section 17(2)(c) and section 18 of the Crown
Employees Collective Bargaining Act, it must be
taken to mean ~that the parties, after considering
the situation of casual employees,, saw fit to
agree that they could be terminated upon one week's
notice. Thus, in attempting to pay heed to the
parties' expressed intentions while at the same
time fulfilling our statutory mandate, we find that
Article 3.3 should guide us in determining the just
and reasonable r.emedy. We therefore find that the
just and reasonable remedy in all the circumstances
(including the terms of the collective agreement)
is one week's notice or one week's pay in lieu thereo
In this case, the grievor received the requisite
notice and she is therefore not entitled to any
further remedy in this respect."
Again at page 21 of the Boucher Award Professor
Prichard states as follows:
II We wish to acknowledge a certain change in
emphasis between our interpretation of Article
3.3 in this award and in our interim award. In
the interim award the issue properly before us
was whether or not the termination of the grievor
fell within our jurisdiction under section 17(2)
of the Crown Employees Collective Bargaining Act.
Our conclusion was that only the Board and not
the employer could decide that question and that
it could only be decided in light of the evidence.
That is the characterization issue. In this award,
in light of the evidence, we have characterized
the circumstances as a disciplinary dismissal and
thus within section 17(2) and thus within our
jurisdiction. We have then gone on to inquire as
to the consequences.of the absence of just cause
and in this context have found Article 3.3 to be
of continuing relevance in specifying the approp-
riate remedy. To this extent we may be differing
from the language we used in part of the interim
award which can be taken to suggest that Article
3.3 is relevant only to non-disciplinary dismissals.
That was a proposition suggested by counsel for the
Ministry at the first hearing which, upon reflection,
. . .,
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does not appear to have merit. It was not adopted
by the Ministry's subsequent counsel. In the resu
the 'characterization" step does not, in our view,
dispose of the relevance of Article 3.3."
It,
In the instant grievance, we have agonized at some
length regarding the appropri.ate remedy. We are unable to con-
elude that the remedy awarded in the Boucher case was in error
in any respect. In our opinion, it would be improper to ignore
the wording of Article 3.11 of the Collective
identical wording as set out in the individual
employment of each Grievor.
In the result, we reiterate our earl
Agreement and the
contracts of
ier finding that
the Grievors were dismissed without just cause. The employment /
records and personndl files of each Grievor. shall be adjusted to
delete any reference to dismissal
provisions of Article 3.11 preven t
the Grievors and also prevent the
for lost wages.
in August of 1982. The
the Board from reinstating
Board from making an award
Accordingly, 'these grievances are allowed i
DATED at Brantford,'Ontario, this 7th day
Ajmil , A.D., 1983. l--e==-
7: 2000
2: 1210
2: 1200
n part.
of
R.L. Verity, Q.C. -- Vice Chairman
"see partial dissent"
L. Robbins -- Member
w W. A. Lobraico--Member
. .
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IN THE MATTER OF AN ARBITRATION
BETWEEN: THE CROWN IN RIGHT OF ONTARIO
(MINISTRY 0F CORRECTIONAL SERVICES)
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THE ONTARIO PUBLIC SERVICE EMPLOYEES UNION
AND IN THE MATTER OF THE GRIEVANCES OF BRIAN MILLER AND CLAIR MacPHAIL
PEiRTIAL - DlssENT
I have reviewed the Award of the Chairman in the above
_ matter. I an able to concur in the finding that the grievors were
dismissed without just cause. However, I must dissent from the
decision with respect to remedy.
On the one hand, the Board has made a finding that the
grievors were dealt with contrary to the collective agreement. On
then other hand, the decision provides cold comfort to the grievers.
as no remedy is provided either by way of reinstatement or compensation.
The reasoning which the Chairman has adopted at pages 7-9
of the Award is based on an earlier decision of Professor Prichard
in Boucher and Trunbley and Ministry of Correctional Services 218/78.
Unfortunately, the reasoning in that decision is flawed, and both
in that case and in the present one, the Board has improperly declined
jurisdiction to remedy the breach of the collective agreement and
to make the qrievors whole.
The Chairman has begun by distinguishing between termination
under Clause 3.11 of the collective agreement (which can take place
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. .
with one week's notice) and dismissal for cause. The latter provision
applies to unclassified staff (often referred to as casuals) by virtue
of Clause 3.14, which states that Article 27 of the collective
agreement (among others) applies to such employees.
Article 27.6.2 of the agreement reads as follows:
"Any employee other than a probationary employee who is
dismissed shall be entitled to file a grievance at the second stage of the grievance procedure provided he does
so within twenty (20) days of the date of the dismissal."
In addition, such employees are also protected by Section 18(2)
,of the Crown Employees Collective Bargaining Act which also allows
such an employee to grieve any dismissal without just cause.
At page six of the Award, the Chairman in this case determines
how to characterize the matter, whether as a termination or a
discharge. It is clear from this portion of the Award that this Board
views termination and dismissal as two separate processes, with
different consequences flowing from each. Once again, the Boucher
case is cited as authority for handling the characterization issue.
Of particular relevance is the following quote which appears
at page six of the Chairman's Award:
"The Ministry may not deprive an en@loyee of his Section 1712) (c)
(now Section 18(Z)) rights by calling a disciplinary dismissal a termination within the meaning of Article 3.3
(now 3.11). Similarly, an employee cannot gain greater rights
by calling a bona fide termination a disciplinary dismissal
in order to come within the terms of Section 17(2) (c). Rather,
after hearing the evidence of all the circumstances surrounding the severing of the employment relationship this Board must
t 12~ -
decide upon the proper characterization of each case.
For those cases characterized as a termination, the employee will be limited to the protection offered by
Article 3.3. For those cases characterized as dismissals, the Ministry must be prepared to meet the requirements of Section 17(2)."
I have no difficulty with ~that portion of the Award. Clearly
the collective agreement sets out two distinct provisions both
concerning the ending of the employment relationship. The Board must
give effect to both provisions and to that extent the characterization
question is always relevant.
The Chairman has then decided that in this case what occurred
.'was in fact a dismissal and that it was without just cause. What
clearly should follow is that is that the dismissal should be remedied
by reinstatement and compensation. Instead, the Chairman, in dealing
with remedy, has now turned back to Clause 3.11 (which relates to
termination), and has used that clause as a justification for effectively
not remedying the dismissal. This is frankly a surprising result,
when, as of page six, the Chairman came to the conclusion that this
was a dismissal rather than a termination.
In fact, the two parts of the Award are inconsistent with
each other. If the matter is a dismissal, then any terms of the
agreement which relate to other methods of ending the employment
relationship are not relevant.
The quote from the Boucher Award which appears at page 7,
clearly contradicts all the earlier findings with respect to the
characterization issue. Note in particular the following:
,......./4
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"The term 'termination' is given no limit in Article 3.3;
it is not limited to situations in which there is no
longer work to be performed. In normal usage it should
be taken as including a dismissal and there is nothing in
the collective agreement to oust the normal interpretation. Thus, on its face, Article 3.3 specifies the scope of protection to be accorded casual employees."
It may be that in some contexts the word "termination" can
be seen as a general term which encompasses all forms of ending the
employment relationship, including dismissal. But in this collective
agreement, where the parties have clearly spelled out two separate
routes, a termination cannot be seen to mean "dismissal" as well. To
.' so hold would be to wipe out the effect of Clause 27.6.2 of the
collective agreement and Section 18(2) of the Act.
The above quotes also lay bare the contradictory reasoning
in the predecessor Boucher Award. In simple terms, the Board, having
gone through a lengthy exercise to decide which of two categories
the events fell into decided that there was in fact only one category
of termination in any case. It is clear that the Board (both in the
predecessor case and the one at hand) cannot have it both ways. If there
are in fact two procedures under the collective agreement, then the
appropriate remedy must flow from each.
Professor Prichard was aware of.the contradictions in his own
award when he stated the following:
"We wish to acknowledge a certain change in emphasis
between our interpretation of Article 3.3 in this award and in our interim award." (quoted at page 8 of the Award)
In my view,
what occurred is more than a change of emphasis
. . . . . . . . /5
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:
but rather is a decision on the question of remedy which is
inconsistent with the finding on the merits.
This problem of characterization is not unique to the
situation for casual staff. There are also a significant number of
awards dealing with probationary employees in the Ontario Public
Service. In that situation, Boards of Arbitration have distinguished
between release and dismissal. In any grievance alleging improper
dismissal of a probationary employee, the Board must first establish
whether what occurred was a release or a dismissal, and then, if the
latter, was it a valid dismissal.
.'
Note the following statement of jurisdiction which appears
in the decision of Mr. Verity in LeBlanc and Ministry of Consumer
and Commercial Relations, 630/81 at pages 12-13:
"The jurisdiction of the Grievance Settlement Board in
'release' cases was set out by the Union concisely as
follows:
1) The Board has jurisdiction to determine if there was a bona fide release made in good faith for
failure to meet the requirements of the job
2) An Employer can't camouflage a discipline or dismissal under the guise of a release
3) The Board must review a contested release to ensure that it is what it purports to be
4) If the Board determines's valid release has taken place it cannot assess the merits of a release
5) The onus is on the Employer to demonstrate that what in form purports to be a release, is in substance a
release."
In the above case, the Board found that what occurred was in fact a
dismissal and that it was without just cause. Note the following
. . . . . . ./6
statement on the question of remedy:
"In the result, the grievor shall be reinstated forthwith
to the position of Examiner, Financial Officer II with the Pension Commission of Ontario. In addition, she will receive monetary compensation minus any salary benefits received in the interim, retroactive to October 1, 1981 when she will be deemed to have achieved seniority Status.”
It is clear then that in the case of probationers, once a
matter has been found to be a dismissal, Boards have accepted the fact
that the appropriate remedy must follow. One does not look to the
"release" situation to determine the remedy which would be appropriate
for a dismissal. : The same must be true in cases involving unclassified
or casual staff.
The Courts have given directions to Boards of Arbitration
on their remedial authority. The Ontario Court of Appeal (Brooke, J.A.)
stated in re Blouin Drywall Contractors Limited and United Brotherhood
of Carpenters and Joiners of America, Local 2486 (1975, 57 D.L.R. (3rd)
200 at p. 210):
"There is no specific Limitation on the jurisdiction of the
Board with respect to monetary awards. It is within the
general jurisdiction of the Board of Arbitration to make a monetary award for breach of the collective agreement
which award is necessary to place the injured grievor in the position he would have been in had the contract been
carried out..."
Also relevant is the decision of the Divisional Court (Reid, Osborne
and Trainor, JJ.) in re Board of Education for Scarborough v. Picher
et, 37 O.R. (7) p. 348. In that case, the Board awarded reinstate-
ment of a probationary employee notwithstanding that the teachers'
. . . . ../l
.r, *
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contract provided that the agreement could be terminated on the 31st day
of August in any year. The Courts upheld the decision and made the
following comments:
"In argument before this Court the penalty was challenged
on a number of grounds. In my opinion, it was open to
the Board of Arbitration to award that penalty. It is an
appropriate response to the action taken by the Board of Education in that it redresses the error. There is nothing
in the collective agreement that in my opinion reduces the
force of the many decisions upholding a Board of Arbitration's
authority to tailor the remedy to the occasion." (at pp. 356-357)
In the case at hand, the fact that the grievors were improperly
dismissed deprived them of the opportunity to continue working through
their contract. It is true that the Employer may have terminated
them under Article 3.11 at some time in any case. However, we do
not know that for a fact. What the Employer might have done under
Article 3.11 is mere speculation. It is equally conceivable that
the Employer would not have terminated the two grievors, and that they
would have been able to continue working throughout the entire period
until the present. In fact, they may also have had their contracts
renewed on April 1, 1983.
In order to make the grievors whole it is therefore essential
that they receive the usual remedies of reinstatement and compensation.
Otherwise, the whole grievance process becomes a meaningless sham
where the grievors get no more than a paper victory and the wrong done
to them is left as is.
Finally, I accept the proposition that generally a Board of
Arbitration should follow the decisions of.other Boards where they
deal with the very same parties and the same language of the collective
. . . . . ../E
.i: ‘r
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li~i i..
agreement. However, such does not apply where the Board is
convinced that the former award is clearly wrong. In the case
at hand, the Boucher Award is in fact inconsistent with itself. In
fact, it can be said that Professor Prichard failed to follow his
own award. Therefore,this is a case where the Board must in fact
come to a different conclusion on the question of remedy.
T.
-. . .
In conclusion, this Award has 'clearly differentiated between
two separate actions of termination and dismissal, and found that what
occurred was a dismissal without just cause. In the face of that
,' finding, the Chairman has improperly treated the case as if it came
under the heading of termination when deciding the question of remedy.
In the result, the Board has improperly declined jurisdiction
to award a remedy which would correct the breach of the collective
agreement and make the grievors whole.
Respectfully submitted
&.~-; /+&&
Larry Robbins ~
Member
Dated this 23'-'daay of March, 1983
at Toronto, Ontario
.
. . .
2s
ze?resex.ed by the i?:itis;ry
cf Ccrrec~ional Services
i+slicazr --
- 2nd -
Res~ondezr
NOTICE OF APPLIC4TION FOR JUDICL4L RECEIVED
%?
-. -2-
1P YOU h'ISB TO OPPOSE TEIS APPL~~~TlDh', you OI
an Ontario lawyer actin: f'or you must fcr:hGizh prepare
a nctice 0: zppeerance In Form 38f prescribed by the Ru?es
of Civil Pzocedcre, serve it on the a>plicezr's lawyer
or, where the applicant does not have a lawyer, serve it
on the a??lican:, and file it, wizh proof of service, in
the office of t he Divisional COW:, and you or you: lawyez
‘YiiL'S' w eppzar 2: zhe hearinS.
IF YOU WISH TO PRESlXT AFFIDAVIT OR OTHER DOCUWXTARY
&UDENCE TO THE COURT OR TO E)CkV.INE k'ITNE.SSES ON THFAPPLIChTIOC,
you or, yocr lawyer mzs;, in adtrior; to serving yocr nc=ice
of 2p?errance, serve a copy of the elYidence on zhe applicant's
lawyef or,.w-here the a@.icar.t does no: have a lawyes,
serve it on :he a??lican:, and file it, %ith :,roof of setvice,
in the office of zhe Divisional Coxt within zhirty days
efter service on you of the applicant's applicarion record,
or not later than 2 2.m. on The 62y before zhe hearing,
w:hichever is earlier.
IF YOU FAIL TO A.PPEwl AT TPr BE&RING, JUDGmT
?SAY~BE GIVEN IN YOUR ABSENCE AND KITBOUT FURTHER NOTICE
TO YOU.
Date:. issued
;0: Gowling and Henderson
Barristers and Solicitors
Suite 2400
2 First Canadian Place
Toronto, Ontario
K5X lA4
Attention: Mr. c. Daliare (416) 862-8484
hND TO: The Grievance Settlement 302rd
Suite 2100 180 Dundas Street West
Toronto, Oncaric, MjG 1Z8
-3-
1. The appiicant(&.) make(s) appliCatiOn for:
m-m- -f c.“ma, An order 'setting aside the decision of the Grievance
Settlemenk Board, dated March 2, 1987 and referring
the matter back to the Board.
2. The grounds fdr the application are:
!zz%o- ==ke- lil’ That the Grievance Settlement Board erred in law and
exceeded its jurisdiction by purporting to reinstate bzmnsin~rurn~ M a., the Gri'evors to positions in the unclassified service;
and /
(ii)' such further and other grounds as counsel may advise.
1
3. The following documentary evidence will be used a: the hearing 01 the application:
I
1. the Record of the Proceedings before the Grievance
Settlement Board; and
2. such further and other material as counsel may
advise.
/
Attornev General for Ontario
Ministr? of the Attorney General
Crown Law Office - Civil
18 King Street East 17th floor
Torcnro, Ontario
F5C ~lC5
.’ .i
HER MAJESTY THE QUEEN Iti RIGliT OF ONTARIQ,, THE'ONTARIO PUBLIC SERVICE EMPLOYEES UtllOll < as represented by the Ninistry of Correctional AWL ICAl4l(S) Services
&&i wr "I WU.".l,I,")
SUPREME COUnT OF ONTAfllO
NOTICE OF APPLICATION
Attorney General for Ontario
Ministry of the Attorney General
Crown Law Office - Civil
18 King St. East, 17th floor
Toronto, Ontario
M5C lC5
Per : Leslie M. McIntosh
Counsel
(416) 965-6878 '