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Judicial Review: When and How to Challenge a Regulatory Decision in Court
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The letter arrived from the provincial food safety authority on a Tuesday afternoon, its 4-page determination concluding that the operator of a small artisanal food processing facility in a mid-sized city in British Columbia would have its processing licence suspended for 90 days effective immediately. The facility, which the operator had built over 7 years into a modest but profitable enterprise producing specialty preserved foods for regional grocery chains and farmers' markets, now sat idle. The regulatory decision cited 3 separate inspection reports from the preceding 18 months, each of which had identified what the authority characterized as recurring deficiencies in the facility's temperature monitoring protocols and record-keeping practices.

The operator had responded to each inspection with corrective measures, had invested approximately $45,000 in upgraded refrigeration equipment after the 2nd inspection, and had hired a part-time food safety consultant to review procedures. The 3rd inspection, conducted 6 weeks before the suspension decision, had noted that while the equipment upgrades were complete, certain documentation requirements remained inconsistent with the authority's expectations. The inspector's report acknowledged the improvements but concluded that the pattern of deficiencies demonstrated a systemic failure to maintain compliance. The authority's hearing panel, which reviewed the inspector's recommendation, held a 2-hour hearing at which the operator appeared without legal counsel and presented documentation of the corrective steps taken. The panel's written decision, issued 3 weeks after the hearing, adopted the inspector's recommendation and imposed the 90-day suspension.

The operator now faces a business crisis. The suspension has already resulted in the loss of 2 major wholesale contracts, and the 12 employees who worked at the facility have been temporarily laid off. The operator believes the hearing panel failed to properly consider the evidence of corrective action, that the inspector's characterization of the deficiencies was unreasonable given the documented improvements, and that the hearing itself was procedurally flawed because the operator was not provided with copies of certain internal communications between the inspector and the authority's compliance division that were referenced in the panel's reasons. The authority's enabling statute provides for an internal appeal to a review board, but the operator has learned that such appeals typically take 4 to 6 months to resolve. The operator has consulted with a lawyer who has advised that judicial review may be available but has raised questions about timing, the requirement to pursue internal remedies, the standard a court would apply to the panel's decision, and whether the procedural concerns could form the basis of a successful challenge.

Judicial Review: What It Is and How It Differs From an Appeal

Judicial review stands as one of the most important safeguards available to Canadians who find themselves on the receiving end of government decisions that affect their livelihoods, their businesses, and their operations. At its core, judicial review is the process by which a court examines a decision made by an administrative body—such as a licensing board, a regulatory agency, a municipal government, or a tribunal—to determine whether that decision was made lawfully and reasonably. This mechanism exists because Canadian law recognizes that while Parliament and provincial legislatures delegate significant decision-making power to administrative bodies, those bodies must exercise that power within certain boundaries. When they exceed those boundaries, or when they exercise their power in ways that are fundamentally unfair or unreasonable, the courts can intervene.

The concept of judicial review is rooted in the constitutional principle that courts have inherent supervisory jurisdiction over administrative decision-makers. This means that regardless of what a statute says about the finality of an administrative decision, the superior courts retain the authority to review that decision for legality. This principle flows from section 96 of the Constitution Act, 1867, which establishes the superior courts of the provinces and, by implication, protects their core supervisory function. The Federal Court exercises similar jurisdiction over federal administrative bodies by virtue of the Federal Courts Act. Understanding this constitutional foundation helps explain why judicial review is available even when a statute appears to prevent it—the power of courts to ensure administrative bodies act within their legal authority cannot be entirely ousted by legislation.

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