R. v. Old Navy Property Corporation

R. v. Old Navy Property Corporation

The Court quashed the appeal because s.16(3) of the CDSA expressly limits the right of appeal from a forfeiture order to the person convicted or the Attorney General; the appellant was neither, and therefore had no statutory right to appeal.

Source-derived case information.

Citation
2014 ONCA 471
Parties
Respondent: Her Majesty the Queen; Appellant: Old Navy Property Corporation
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
16 June 2014
Procedural Posture
Criminal Forfeiture Under the Controlled Drugs and Substances Act / Appeal to the Court of Appeal From a Forfeiture Order Under S.16 CDSA
Outcome
Appeal quashed
Legal Topics
Forfeiture, Right of Appeal, Controlled Drugs and Substances Act S.16, Third Party Standing
Source Language
en
Criminal Law Statutory Interpretation Procedural Law Forfeiture Right of Appeal Controlled Drugs and Substances Act S.16 Third Party Standing

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Parties

Her Majesty the Queen

Respondent

Old Navy Property Corporation

Appellant

Procedural Posture

Criminal Forfeiture Under the Controlled Drugs and Substances Act / Appeal to the Court of Appeal From a Forfeiture Order Under S.16 CDSA

  1. 1 Whether a non‑convicted third party has a right of appeal from a s.16 forfeiture order under the CDSA
  2. 2 Whether the anomaly between s.16 and s.20 creates a right of appeal for third parties
  3. 3 Whether the clear language of s.16(3) permits the appellant to appeal

Ratio Decidendi

The Court quashed the appeal because s.16(3) of the CDSA expressly limits the right of appeal from a forfeiture order to the person convicted or the Attorney General; the appellant was neither, and therefore had no statutory right to appeal.

Court Disposition

Appeal quashed

Orders

  • Appeal quashed