Nova Scotia (Health) v. Dickie

Nova Scotia (Health) v. Dickie

Because s.41(2) of the Freedom of Information Act required the head of the Department to give notice to the third party on receipt of the appeal and that notice had not been given, the Supreme Court lacked jurisdiction to order further disclosure; the Supreme Court's judgment was therefore set aside and the matter...

Source-derived case information.

Citation
1997 NSCA 32
Parties
Appellant: The Department of Health; Respondent: Sharon Dickie
Court
Nova Scotia Court of Appeal
Jurisdiction
Canada
Judgment Date
10 January 1997
Procedural Posture
Appeal Under the Freedom of Information Act / Court of Appeal Decision (oral Reasons)
Outcome
Appeal allowed; Supreme Court judgment set aside for lack of jurisdiction; matter remitted for new hearing after required notice; no order for costs.
Legal Topics
Freedom of Information, Disclosure, Notice to Third Parties, Jurisdiction, Remittal
Source Language
en
Administrative Law Access to Information Law Freedom of Information Disclosure Notice to Third Parties Jurisdiction Remittal

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Legal principles 2 Authorities cited 1 Party arguments 2
Sign in to unlock

Parties

The Department of Health

Appellant

Sharon Dickie

Respondent

Procedural Posture

Appeal Under the Freedom of Information Act / Court of Appeal Decision (oral Reasons)

  1. 1 Whether failure to give statutorily required notice to a third party under s.41(2) of the Freedom of Information Act deprived the Supreme Court of jurisdiction
  2. 2 Whether the Supreme Court's order for further disclosure must be set aside and the matter remitted for a new hearing after proper notice

Ratio Decidendi

Because s.41(2) of the Freedom of Information Act required the head of the Department to give notice to the third party on receipt of the appeal and that notice had not been given, the Supreme Court lacked jurisdiction to order further disclosure; the Supreme Court's judgment was therefore set aside and the matter remitted for a new hearing after the requisite notice is given.

Court Disposition

Appeal allowed; Supreme Court judgment set aside for lack of jurisdiction; matter remitted for new hearing after required notice; no order for costs.

Orders

  • Judgment of the Supreme Court set aside as having been made without jurisdiction
  • Matter remitted to the Supreme Court for a new hearing after the head of the Department gives the requisite notice to the third party under s.41(2) of the Freedom of Information Act