Kelly Properties v. Canadian Council of Professional Engineers

Kelly Properties v. Canadian Council of Professional Engineers

The Federal Court judge committed a palpable and overriding error in finding the additional affidavits would have materially affected the TMOB outcome; the affidavits offering expert opinion on the Alberta statute and association guidelines were irrelevant because the statute was already in evidence; the Federal...

Source-derived case information.

Citation
2013 FCA 287
Parties
Appellant: Kelly Properties; Respondent: Canadian Council of Professional Engineers
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
3 December 2013
Procedural Posture
Appeal to Federal Court of Appeal From Federal Court Judicial Review of Trade Marks Opposition Board Decision / Judgment on Appeal (federal Court of Appeal)
Outcome
Appeal allowed; judgment of the Federal Court set aside; on proper review the appeal from the TMOB is dismissed with costs
Legal Topics
Trademark Opposition, Standard of Review (reasonableness), Admissibility of Fresh Evidence on Judicial Review, Expert Evidence on Statutory Interpretation
Source Language
en
Trademark Law Administrative Law Judicial Review Trademark Opposition Standard of Review (reasonableness) Admissibility of Fresh Evidence on Judicial Review Expert Evidence on Statutory Interpretation

Source-derived case record

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Parties

Kelly Properties

Appellant

Canadian Council of Professional Engineers

Respondent

Procedural Posture

Appeal to Federal Court of Appeal From Federal Court Judicial Review of Trade Marks Opposition Board Decision / Judgment on Appeal (federal Court of Appeal)

  1. 1 Whether the Federal Court judge erred in admitting and giving weight to additional affidavits not before the TMOB
  2. 2 Whether expert opinions on statutory interpretation and association guidelines are relevant on judicial review of an administrative decision
  3. 3 What standard of review (reasonableness) should apply to the TMOB decision

Ratio Decidendi

The Federal Court judge committed a palpable and overriding error in finding the additional affidavits would have materially affected the TMOB outcome; the affidavits offering expert opinion on the Alberta statute and association guidelines were irrelevant because the statute was already in evidence; the Federal Court should have applied a reasonableness standard to the TMOB decision; the TMOB decision was not unreasonable and must be upheld.

Court Disposition

Appeal allowed; judgment of the Federal Court set aside; on proper review the appeal from the TMOB is dismissed with costs

Orders

  • Appeal allowed with costs
  • Judgment of the Federal Court set aside