Ontario (Funeral, Burial and Cremation Services Act, 2002, Registrar) v. 1868653 Ontario Inc. (Newcastle Funeral Home Ltd.)

Ontario (Funeral, Burial and Cremation Services Act, 2002, Registrar) v. 1868653 Ontario Inc. (Newcastle Funeral Home Ltd.)

The Registrar failed to discharge the statutory onus under s.14(1)(d)(iii) to establish reasonable grounds of risk to public health and safety; the Licence Appeal Tribunal's factual findings that there was no evidence the respondent's low temperature alkaline hydrolysis did not destroy prions were entitled to...

Source-derived case information.

Citation
2020 ONCA 771
Parties
Appellant: Registrar, Funeral, Burial, and Cremation Services Act, 2002; Respondent: 1868653 Ontario Inc. o/a Newcastle Funeral Home Ltd.
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
3 December 2020
Procedural Posture
Appeal (administrative Law) / Court of Appeal Decision on Appeal From Divisional Court
Outcome
Appeal dismissed
Legal Topics
Standard of Review/deference, Precautionary Principle, Statutory Onus, Tribunal Fact Finding, Licence Regulation
Source Language
en
Administrative Law Public Health Law Regulatory Law (funeral Services) Standard of Review/deference Precautionary Principle Statutory Onus Tribunal Fact Finding Licence Regulation

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Parties

Registrar, Funeral, Burial, and Cremation Services Act, 2002

Appellant

1868653 Ontario Inc. o/a Newcastle Funeral Home Ltd.

Respondent

Procedural Posture

Appeal (administrative Law) / Court of Appeal Decision on Appeal From Divisional Court

  1. 1 Whether the Registrar met the statutory test in s.14(1)(d)(iii) of the Funeral, Burial and Cremation Services Act, 2002 by establishing reasonable grounds to believe the respondent's operation was a risk to public health and safety
  2. 2 Whether the report of Public Health Ontario and evidence of Dr. Copes constituted reasonable grounds to believe there was a public health risk
  3. 3 Whether the precautionary principle applied

Ratio Decidendi

The Registrar failed to discharge the statutory onus under s.14(1)(d)(iii) to establish reasonable grounds of risk to public health and safety; the Licence Appeal Tribunal's factual findings that there was no evidence the respondent's low temperature alkaline hydrolysis did not destroy prions were entitled to deference, so the precautionary principle did not apply and the Tribunal did not err in not imposing conditions not raised before it.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Costs to respondent in the amount of $30,000 inclusive of disbursements and all applicable taxes