Metropolitan Toronto Police Services Board v. Dr. Young

Metropolitan Toronto Police Services Board v. Dr. Young

The Court held that Dr. Young's attendance at the meeting to ensure the reliability of an expert report did not create a reasonable apprehension of bias, and that the Coroners Act provided statutory authority for his participation; accordingly the Divisional Court's finding of bias was set aside.

Source-derived case information.

Citation
C27755
Parties
Applicant/respondent: Metropolitan Toronto Police Services Board; Applicant/respondent: Chief of Police David J. Boothby; Respondent/appellant: Dr. James Young; Applicant/respondent: Nick Ashley; Applicant/respondent: William Kemp; Applicant/respondent: Terrence Rivers; Respondent: Black Action Defence Committee; Respondent: Special Investigations Unit; Applicant/respondent: Paul Van Seters
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
13 November 1998
Procedural Posture
Judicial Review / Appeal to Court of Appeal
Outcome
Appeal allowed; judgment of the Divisional Court set aside; application for judicial review dismissed
Legal Topics
Reasonable Apprehension of Bias, Coroners' Duties, Statutory Authority Under Coroners Act, Costs
Source Language
en
Administrative Law Judicial Review Civil Procedure Reasonable Apprehension of Bias Coroners' Duties Statutory Authority Under Coroners Act Costs

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Parties

Metropolitan Toronto Police Services Board

Applicant/respondent

Chief of Police David J. Boothby

Applicant/respondent

Dr. James Young

Respondent/appellant

Nick Ashley

Applicant/respondent

William Kemp

Applicant/respondent

Terrence Rivers

Applicant/respondent

Black Action Defence Committee

Respondent

Special Investigations Unit

Respondent

Paul Van Seters

Applicant/respondent

Procedural Posture

Judicial Review / Appeal to Court of Appeal

  1. 1 Whether Dr. Young's presence at a December 2, 1993 meeting created a reasonable apprehension of bias
  2. 2 Whether the Chief Coroner had statutory authority to participate in investigative meetings under the Coroners Act
  3. 3 Whether ensuring reliability of an expert report by the coroner amounts to a disqualifying bias

Ratio Decidendi

The Court held that Dr. Young's attendance at the meeting to ensure the reliability of an expert report did not create a reasonable apprehension of bias, and that the Coroners Act provided statutory authority for his participation; accordingly the Divisional Court's finding of bias was set aside.

Court Disposition

Appeal allowed; judgment of the Divisional Court set aside; application for judicial review dismissed

Orders

  • Appeal allowed
  • Judgment of the Divisional Court set aside