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A-298-80
The Queen (Applicant) v.
H. Khan, D. F. Marchand, S. S. Martucci, F. Ott, L. Purvey and I. J. Williams (Respondents)
Court of Appeal, Ryan and Le Dain JJ., MacKay D.J.—Toronto, December 8 and 11, 1980.
Judicial review — Public Service — Respondents eliminated from closed competition in view of their results in the General Administrative Ability Test — Application to review and set aside decision of Appeal Board that the majority of questions in the test were not relevant to the abilities required for the position — Whether Appeal Board erred in law — Public Service Employment Act, R.S.C. 1970, c. P-32, ss. 10, 21 — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28.
This is a section 28 application to review and set aside the decision of an Appeal Board allowing the appeals of the respondents who were eliminated from a closed competition because of their results in the General Administrative Ability Test. The Board held that the majority of the questions in the test were not relevant to the two ability sub-factors it was supposed to assess, having regard to the duties of the position under competition. The question is whether the Board erred in law in so deciding.
Held, the application is dismissed. Whether a particular selection process is in fact designed or calculated to establish the merit of candidates in relation to the qualifications for a position is subject to review by an appeal board pursuant to section 21 of the Public Service Employment Act. An appeal board may allow an appeal on the ground that the selection process or a substantial or decisive part of it was not suitable for assessing merit in relation to certain of the qualifications for the position. The question whether a particular part of the selection process is a true test of merit is one of fact. It is not for this Court to substitute its opinion for that of the Appeal Board.
APPLICATION for judicial review. COUNSEL:
W. L. Nisbet, Q.C. for applicant.
M. W. Wright, Q.C. for H. Khan.
No one appearing for other respondents.
SOLICITORS:
Deputy Attorney General of Canada for applicant.
Soloway, Wright, Houston, Greenberg, O'Grady, Morin, Ottawa, for H. Khan.
The following are the reasons for judgment delivered orally in English by
LE DAIN J.: This is a section 28 application to review and set aside the decision of an Appeal Board under section 21 of the Public Service Employment Act, R.S.C. 1970, c. P-32. The Board allowed the appeals of the respondents, who were unsuccessful candidates in a closed competition to select persons for appointment to the position of shift supervisor in mail processing facilities of the Post Office in the Metro Toronto region, on the ground that they were eliminated from the compe tition on the basis of the results in a test that was not relevant to the abilities that it was supposed to assess. The Crown brings the section 28 applica tion on the ground that in so deciding the Appeal Board erred in law.
The notice of the competition described the duties of the position of shift supervisor. A state ment of qualifications set forth certain "basic requirements", the nature of which do not concern us here, and certain "rated requirements", which included a knowledge requirement, an ability requirement, and a personal suitability require ment. The ability requirement, which is the one in issue, reads as follows:
Ability
1. Ability to supervise in terms of assigning work, training and developing employees, counselling, appraising work perform ance and recommending disciplinary action.
2. Ability to anticipate, plan and organize work, set priorities and allocate staff.
3. Ability to analyze problem situations within the work unit and recommend solutions.
4. Ability to communicate effectively, orally and in writing with supervisors, peers, subordinates, customers and officials of a variety of organizations who may come in contact with the department.
The selection process was carried out in several stages. In the first stage a screening board found that of the 135 candidates in the competition, 69, including the respondents, met the basic require ments of the position. These 69 were then given the Public Service Commission's General Adminis trative Ability Test, Examination E-280A, to assess the second and third of the ability factors
quoted above and referred to in the reasons of the Appeal Board as "sub-factors". These two sub-fac tors were together assigned a maximum of 28 marks. The other two ability sub-factors were assigned a maximum of 6 marks each, making a total maximum of 40 marks for the ability require ment as a whole. The passing score for the ability requirement as a whole was 60% or 24 marks. In order to be assessed on the remaining two ability sub-factors candidates had to obtain a total of at least 12 marks on the second and third sub-factors. Twenty-four of the candidates answered at least 27 of the 65 questions in the General Administra tive Ability Test correctly and were awarded at least 12 marks out of the maximum of 28 on the second and third ability sub-factors. They were then assessed by a rating board with respect to the knowledge requirement, and those who obtained at least 60% of this requirement were assessed by another rating board with respect to the other two ability sub-factors and the personal suitability requirement. Seven candidates were found to be qualified as a result of the entire selection process and were placed on an "eligible list" in order of merit. The respondents received less than a total of 12 marks on the second and third ability sub-fac tors as a result of their answers on the General Administrative Ability Test, and since they would, therefore, be unable to obtain the minimum of 60% or 28 marks on the ability requirement as a whole, even if they obtained the maximum of 6 marks on each of the other two ability sub-factors, they were not assessed with respect to the other rated requirements and were in effect eliminated from the competition.
On their appeal the respondents contended that 58 of the 65 questions on the General Administra tive Ability Test did not elicit information upon which the selection board could have assessed the candidates against the "ability to anticipate, plan and organize work, set priorities and allocate staff' and the "ability to analyze problem situa tions within the work unit and recommend solu tions." The respondents contended that certain of the questions elicited information with respect to other abilities and a considerable number of them "were not related to the duties and responsibilities
of the position under competition". The respond ents' contention was in substance upheld by the Appeal Board.
The content of the General Administrative Abil ity Test was, at the request of the Public Service Commission, treated as confidential by the Appeal Board, and by order of the Court in these section 28 proceedings it was directed to be bound separately from the other material in the case, to be marked confidential, and to be available to counsel upon an undertaking to maintain its confi dentiality except as prescribed by the order and permitted by the Court in the course of argument. It is, therefore, only possible to refer to the test in general terms. According to the explanatory ma terial on the test, which forms part of the non-con fidential record, it was developed for the Public Service Commission by the Personnel Psychology Centre (PPC) as "a selection test for certain entry- level positions within the Administrative and For eign Service Category (AFSC) of the Canadian Public Service." It is said to be designed to assess certain "component abilities", which I quote because they are referred to in the reasons of the Appeal Board:
• the ability to place information in the proper order or best sequence (i.e., Ability to Analyze and Evaluate, Ability to Plan, Ability to Organize)
• the ability to select and organize relevant information for the solution of a problem (i.e., Ability to Analyze and Evaluate)
• the ability to draw conclusions based on given information (i.e., Ability to Analyze and Evaluate, Ability to Control)
• the ability to anticipate the needs or consequences of a given situation (i.e., Ability to Plan, Organize, Ability to Direct)
• the ability to follow directions and to evaluate information according to specified criteria (i.e. Ability to Control)
• the ability to recognize effective written communication (i.e., Ability to Communicate in Writing)
It is not clear from the record whether the position of shift supervisor in the Post Office would be considered to be an "entry-level position within the Administrative and Foreign Service
Category", although it is a possible implication of the reasons of the Appeal Board that it would not. The use of the General Administrative Ability Test by a selection board is optional, but thè explanatory material states that the test, which consists of 65 multiple choice questions, must be used in its entirety. The material states that "Un- der no circumstances can the component parts of the test be administered as separate assessment instruments." In the present case the candidates were required to answer all the questions.
The general conclusion of the Appeal Board as to the suitability of the test for assessment of the second and third ability sub-factors is contained in the following passages from the Chairman's reasons:
After carefully considering the evidence relative to the first allegation, 1 am of the opinion that most of the questions asked on the Public Service Commission's General Administrative Ability Test, Examination E-280A, did not elicit information upon which the selection board could have assessed the candi dates against the "ability to anticipate, plan and organize work, set priorities and allocate staff' and "ability to analyze prob lem situations within the work unit and recommend solutions" sub-factors of the "Abilities" rating factor. As the Department so aptly pointed out, those "abilities" are required in order to perform specific duties of the positions under competition. Therefore, any questions asked must elicit information so that the selection board can assess the candidates against those two sub-factors in relation to duties to be performed.
The questions on the examination, which I have refrained from reproducing at the Department's request, may very well provide information upon which to assess candidates against the component abilities, but that is a matter which is not in issue. Therefore, I will only consider the questions in relation to the sub-factors and duties of the positions under competition, and decide upon their relevancy or applicability, accordingly.
In the result, the Appeal Board found that only seven of the 65 questions on the test were "reason- ably related to those `abilities' in the context of the duties to be performed". In allowing the appeals on this ground the Board pointed out that it was not challenging the validity of the General Administrative Ability Test for the purpose for which it was designed. On this point the Chairman said:
In conclusion, I wish to state that since the issue in these cases was not the validity of the Public Service Commission's General Administrative Ability Test, Examination E-280A, as a selection tool for assessing candidates for certain entry-level
positions within the Administrative and Foreign Service Cate gory, nothing in this decision should be inferred as indicating that it was in any way deficient in that respect.
The issue is whether the Appeal Board commit ted an error for which its decision may be set aside under section 28 of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, in allowing the appeals of the respondents on the sole ground that all but seven of the 65 questions on the General Adminis trative Ability Test did not elicit information upon which the selection board could have assessed the candidates against the "ability to anticipate, plan and organize work, set priorities and allocate staff" and the "ability to analyze problem situa tions within the work unit and recommend solu tions", having regard to the duties of the particular positions under competition.
Section 10 of the Public Service Employment Act provides that appointments to positions in the Public Service "shall be based on selection accord ing to merit" and that they shall be made by competition or other selection process "designed to establish the merit of candidates". The selection process is to be determined by the Public Service Commission, or those acting for it in a particular case, but whether a particular selection process is in fact designed or calculated to establish the merit of candidates in relation to the qualifications for a position is subject to review by an appeal board on an appeal under section 21 of the Act. An appeal board may allow an appeal on the ground that the selection process or a substantial or decisive part of it was not suitable for assessing merit in relation to certain of the qualifications for the position. In considering that question in the present case the Appeal Board did not, therefore, exceed its author ity or misdirect itself in law. The question whether a particular part of the selection process is a true test of merit in relation to certain qualifications for the position is one of fact. The Appeal Board concluded that only seven of the 65 questions on the General Administrative Ability Test would elicit information on which the selection board could have assessed the candidates against the two abilities in issue. In this Court, counsel for the Crown contended that at least 30 of the 65 ques tions, or less than half, were suitable for this
purpose. It is not for us to substitute our opinion for that of the Appeal Board on this disputed question of fact. On the material before us it cannot be said, in my opinion, that the applicant has discharged the burden of establishing that the decision of the Appeal Board was based on an erroneous finding of fact of the kind described in section 28(1)(c) of the Federal Court Act or on a conclusion that would otherwise amount to an error of law. I would accordingly dismiss the sec tion 28 application.
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RYAN J. concurred.
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MACKAY D.J. concurred.
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