N., D. v. The Children's Aid Society of the Niagara Region

N., D. v. The Children's Aid Society of the Niagara Region

The appeal was dismissed because the Superior Court correctly declined to exercise judicial review/habeas corpus jurisdiction where an effective alternative remedy existed in ongoing Ontario Court of Justice proceedings, leave refusal under s.6(2) JRPA is not appealable, and there was no legislative gap since the...

Source-derived case information.

Citation
C42182
Parties
Appellant: D.N. (an infant) by his Litigation Guardian N.N.; Appellant: N.N.; Respondent: The Children's Aid Society of the Niagara Region; Respondent: J.N.; Respondent: The Attorney General for Ontario; Respondent: Constable Tracy McCabe
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
15 December 2004
Procedural Posture
Judicial Review / Habeas Corpus Proceedings Arising From Family Law Apprehension / Appeal to Court of Appeal From Superior Court Order
Outcome
Appeal dismissed.
Legal Topics
Parens Patriae Jurisdiction, Habeas Corpus, Judicial Review, Leave Under Judicial Review Procedure Act, Alternative Remedy Doctrine
Source Language
en
Family Law Administrative Law Civil Procedure Parens Patriae Jurisdiction Habeas Corpus Judicial Review Leave Under Judicial Review Procedure Act Alternative Remedy Doctrine

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Legal principles 3 Authorities cited 2 Party arguments 2
Sign in to unlock

Parties

D.N. (an infant) by his Litigation Guardian N.N.

Appellant

N.N.

Appellant

The Children's Aid Society of the Niagara Region

Respondent

J.N.

Respondent

The Attorney General for Ontario

Respondent

Constable Tracy McCabe

Respondent

Procedural Posture

Judicial Review / Habeas Corpus Proceedings Arising From Family Law Apprehension / Appeal to Court of Appeal From Superior Court Order

  1. 1 Whether the Superior Court erred in declining jurisdiction to grant judicial review given ongoing Ontario Court of Justice proceedings
  2. 2 Whether an appeal lies from the refusal to grant leave under s.6(2) of the Judicial Review Procedure Act
  3. 3 Whether parens patriae jurisdiction or habeas corpus was available where the child was detained pursuant to valid court orders and there is an alternative statutory scheme

Ratio Decidendi

The appeal was dismissed because the Superior Court correctly declined to exercise judicial review/habeas corpus jurisdiction where an effective alternative remedy existed in ongoing Ontario Court of Justice proceedings, leave refusal under s.6(2) JRPA is not appealable, and there was no legislative gap since the child was detained pursuant to valid court orders.

Court Disposition

Appeal dismissed.

Orders

  • Appeal dismissed.