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A-359-80
Bernard W. Evans (Applicant) v.
Public Service Commission Appeal Board (Respondent)
Court of Appeal, Ryan and Le Dain JJ. and Kerr D.J.—Ottawa, January 29 and May 21, 1981.
Judicial review — Public Service — Application to review and set aside decision of Appeal Board dismissing the appli cant's appeal against appointments to be made for the position of Senior Correctional Officer — Although applicant had been a correctional officer, the selection board found him unquali fied because he failed to obtain a passing mark on "Potential for Effectiveness" — Selection board's assessment based on direction by Commissioner of Corrections that applicant not be employed in an institution or have contact with inmates — Applicant alleged to have precipitated a rioting incident Whether selection board failed to act in accordance with merit principle and with fairness — Application dismissed — Public Service Employment Act, R.S.C. 1970, c. P-32, s. 21 — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28.
This is an application to review and set aside the respondent Board's decision dismissing the applicant's appeal against appointments to be made from eligibility lists for the position of Senior Correctional Officer. On the applicant's first appeal, the Appeal Board held that the selection board failed to make a proper assessment of his "Potential for Effectiveness". The selection board was reconvened, but it reaffirmed its original assessment. The applicant, a correctional officer, was assigned to other duties in 1977 as a result of the publicity given to the allegation or finding by a parliamentary sub-committee that he had precipitated a riot at Millhaven Institution in 1976. Because the selection board decided not to award him any marks in respect of personal appraisal, the applicant failed to obtain a passing mark on the "Potential for Effectiveness" factor and was thus found unqualified. The selection board's assessment was based on the direction made by the Commis sioner of Corrections following the rioting incident that appli cant was not to be employed in an institution or have contact with inmates. The applicant contends that the selection board failed to act in accordance with the merit principle and to treat him with fairness by failing to offer him an opportunity to be heard with respect to the Commissioner's memorandum on which it based its assessment.
Held, the application is dismissed. The selection board did not fail to act in accordance with the merit principle when in the very special circumstances of this case it based its overall assessment of the applicant's "Potential for Effectiveness" on the Commissioner's judgment as to the likely effect of the public perception of the applicant's responsibility for the dis turbance in the Millhaven Institution in 1976. The assessment
could not have been ignored by the selection board. To have done so would have been to have failed to act in accordance with the merit principle and to conclude on some other basis, not related to all the pertinent facts, that there was potential for effectiveness, when there was reason to believe that it did not exist. The restriction of applicant's employment placed by the Commissioner had a bearing on the entire question of potential for effectiveness or suitability. With respect to the question of fairness, a selection board is not obliged to hear candidates in a competition in so far as that implies a right to present evidence and submit arguments concerning disputed questions of fact or law. Its task is to set the examination or evaluative process, to carry it out and to determine the results. It is not the function of a selection board to review personal appraisal reports: it must take a report as it finds it. The Commissioner's memorandum with respect to employment of the applicant was in the same category.
Nicholson v. Haldimand-Norfolk Regional Board of Commissioners of Police [1979] 1 S.C.R. 311, referred to.
APPLICATION for judicial review. COUNSEL:
Maurice W. Wright, Q.C. and A. J. Raven for
applicant.
Walter L. Nisbet, Q.C. for respondent.
SOLICITORS:
Soloway, Wright, Houston, Greenberg, O'Grady, Morin, Ottawa, for applicant. Deputy Attorney General of Canada for respondent.
The following are the reasons for judgment rendered in English by
LE RAIN J.: This is a section 28 application to review and set aside the decision on May 16, 1980 of an Appeal Board under the Public Service Employment Act, R.S.C. 1970, c. P-32, dismissing the applicant's appeal, pursuant to section 21 of the Act, against the appointments to be made from two eligible lists established by a selection or rating board for the position of Senior Correction al Officer (CX-COF-3 and CX-COF-4) in institu tions in the Ontario Region of the Correctional Service of Canada, Department of the Solicitor General.
The decision under attack is related to that of another Appeal Board on January 7, 1980, which allowed the applicant's appeal against the selection of the successful candidates on the ground that he
had not been properly assessed in respect of one of the rating factors. As a result of that decision the selection board was reconvened, but it confirmed its original assessment. It was against this reaf firmed selection that the second appeal was brought.
The disputed selection was based on a closed competition conducted pursuant to section 5(1)(b)(i) of the Public Service Employment Regulations, C.R.C. 1978, Vol. XIV, c. 1337. The applicant, who had been a correctional officer in the Penitentiary Service for several years, was among the candidates who passed the initial screening as possessing the "Basic Qualifications" described in the notice of competition as follows:
Evidence, through work history, of capability to satisfactorily perform Correctional Officer duties in a minimum, medium or maximum security institution. Such evidence would normally be required as a result of several years experience as a Correc tional Officer.
He was also among the candidates who obtained a passing mark in respect of the essential qualifica tions or rating factors "Knowledge" and "Abili- ties". He was found by the selection board, how ever, to be unqualified, and was therefore not placed on the eligible lists, because he failed to obtain a passing mark on the rating factor "Poten- tial for Effectiveness", which was referred to in the statement of qualifications as follows:
Potential for Effectiveness
Overview of total suitability—
Some such attributes which may be considered are:
Ability to establish and maintain good working relationships.
Stability, reliability, self confidence, and maturity.
Judgement, initiative, discretion and persuasiveness.
Evidence of a positive attitude towards the inmate training and
rehabilitation program.
Ability to adapt to a new environment.
This factor was to be assessed in part on the basis of an interview, which accounted for a total of 50 out of a possible 70 marks for the factor as a whole, and in part on the basis of information in the candidate's performance appraisal report, which accounted for the remaining 20 marks out of the possible 70. Fifteen of these 20 marks were allotted to what was said in the personal appraisal report about "responsibilities and skills" and the remaining five for what was said about "promota-
bility". The applicant was awarded 36 marks out of 50 for his performance in the interview, but he received no marks on the basis of a personal appraisal report, with the result that he failed to obtain the overall passing mark of 42 out of 70, or 60%, on the "Potential for Effectiveness" factor.
The selection board based its assessment of the applicant, in so far as a personal appraisal report was concerned, on the fact that, for reasons which will appear, the Commissioner of Corrections directed that the applicant, although still holding the position of Correctional Officer (CX-COF-2), could no longer be assigned to the duties of that position. The applicant, who had been a correc tional officer in the Millhaven Institution for several years, had been removed from that Institu tion in 1977 on the direction of the Commissioner and been assigned to other duties in Regional Headquarters. In response to the request for the latest "Performance Review and Appraisal Report" for the applicant in the form approved for the Correctional Service there was submitted for consideration by the selection board a memoran dum dated August 16, 1979 and entitled "Perfor- mance Review & Appraisal Mr. B. Evans" from Mr. R. Surgenor, Regional Chief, Preventive Security, who was the applicant's immediate supervisor in the Division of the Correctional Ser vice to which he had been assigned. The memoran dum stated that no one in the Division was quali fied to assess the applicant as a correctional officer because he had not performed any of the duties of that position since joining the staff of the Division. With reference to the applicant's removal from the duties of a correctional officer the memorandum stated, "He labours under a restriction imposed by the Commissioner of Corrections, that he is not to be employed in an institution or have contact with inmates." The memorandum commented on the applicant's attitude and performance in his new duties and then gave the following assessment:
I assess Mr. Evans as a personable individual, intelligent and I am sure, capable. I have little doubt that he has the ability to perform at a highly acceptable level when employed in a position in which he is interested sufficiently to apply himself properly. 1 have considerable sympathy for Mr. Evans concern ing the position in which he finds himself but confess to little sympathy towards his attitude concerning that position. Mr. Evans has potential of that I am certain. I regret that under present circumstances that potential is not and will not be realized.
On the applicant's first appeal, the position of the Department was that the decision of the selec tion board to award the applicant no marks in respect of personal appraisal was based entirely on the statement in the Surgenor memorandum that the applicant "labours under a restriction imposed by the Commissioner of Corrections, that he is not to be employed in an institution or have contact with inmates." The Appeal Board held that the selection board had not made a proper assessment of the applicant's "Potential for Effectiveness" in so far as it had been based on this restriction of the applicant's employment. The Chairman said:
I will not comment on whether Mr. Surgenor's letter constitut ed a valid appraisal for the purpose of this competition since the Rating Board chose to ignore most of this letter and made its decision to fail the appellant on "Potential for Effectiveness" on the basis of a single statement in the letter. I note that appellant Evans' representative called no evidence to refute the Department's contention that Mr. Evans had been restricted from working with inmates by the Minister of the Department and, therefore, on the balance of probabilities, I am prepared to accept that Mr. Evans has been so restricted. Whether or not the Minister has the authority to make such a restriction, and I consider it unnecessary to make a finding in this regard, in my view it is not reasonable to conclude that a candidate lacks "Potential for Effectiveness" simply because the Minister has said he cannot work with inmates. The responsibility for assess ing candidates in a competition lies with the Rating Board and not with the Minister. It is incumbent upon a Rating Board to make an independent assessment of candidates qualifications and to make appointments to positions on the basis of merit. This would not preclude any power the Minister may have under section 8(2) of the Canadian Penitentiary Act to suspend from duty employees appointed by virtue of the competition process.
If the Rating Board had investigated the reasons for the restriction placed on appellant Evans' work activities and had discovered valid evidence that Mr. Evans was personally unsuit ed for working with inmates then I would not fault the Board for concluding that appellant Evans lacked "Potential for Effectiveness". However, according to the Department's state ments at the appeal hearing, no attempt was made by the Rating Board to ascertain why such a restriction had been placed on Mr. Evans' job mobility. It is possible that the Minister issued the restriction for reasons totally unrelated to appellant Evans' "Potential for Effectiveness", for example, he may have felt that Mr. Evans lacked the "Knowledge" to work with inmates. In my opinion, the Rating Board erred in the way in which they assessed Mr. Evans against the "Potential for Effectiveness" factor.
Following the decision of the first Appeal Board allowing the applicant's appeal for the reason indicated in the foregoing passages, Mr. Bruce
Marsh, Regional Staffing Consultant of the Public Service Commission, wrote on January 11, 1980 to Mr. Conrad Weck, Regional Chief, Staffing and Manpower Planning, Canadian Penitentiary Ser vice, as follows:
1 wish to confirm our telephone conversation of 10 January, 1980, regarding the successful appeal of Mr. B. Evans against the results of competition 79-CPS -ONT -CC-5.
The thrust of the Appeal Board's decision would indicate that the Department failed to document their reasons for not quali fying the appellant in accordance with the selection standards (i.e. merit). It would, therefore, be appropriate to re-assess Mr. Evans under the potential for effectiveness factor and fully document the Department's rating and rationale. New appeal rights should then be granted accordingly.
On February 8, 1980, Mr. A. M. Trono, Regional Director General (Ontario) of the Cor rectional Service, wrote a memorandum to Mr. Week enclosing a memorandum from the Commis sioner of Corrections to which he referred as follows:
This memo was written as a result of the Appeals Officer's comment and the PSC instruction relative to the recent CX 3-4 competition. The memo should now be referred to the Selection Board and the Board instructed to review Mr. Evan's applica tion taking cognizance of the Commissioner's statement. Should the Board, after reviewing all pertinent information again fail to qualify Mr. Evans, the Subject will again have right to appeal.
The Commissioner's memorandum to Mr. Trono, which must, I think, because of its impor tance in this case, be quoted in full, reads as follows:
I wish to confirm direction which I have given you regarding assignments of the above employee, and several conversations we have had on the subject.
As you are aware, Mr. Evans was named by the Parliamentary sub-committee on the penitentiary system in Canada as having precipitated a riot at Millhaven Institution on October 5, 1976, as a result of "insulting remarks" made over a loud-hailer to inmates in the exercise yard. The fact that such a statement was made by a group of Members of Parliament cannot fail to make a strong impression on the inmates. In their minds, 1 am certain that the sub-committee confirmed their previous unsub stantiated allegations about Evans' treatment of inmates. I have to conclude that there is a strong possibility of disturbance by inmates, involving the potential for injury to Evans, other members of staff, and to the inmates themselves, if he were to continue to perform the duties of a correctional officer in an institution. Furthermore, there is in my mind a strong possibili ty that the inmates would blame Evans for any incident that might occur, whether or not he had any connection with it. This not only reinforces the possibility of injury to Evans personally, but would make it more difficult to identify the real source of
incidents which might occur. Consequently, I have concluded that the continued employment of Mr. Evans on institutional duties generates a degree of risk which is unacceptable to the best interests of the Service, its employees and the inmate population.
I am aware that Evans had not had the opportunity to respond in any formal way to the statements of the sub-committee. He believes that given such an opportunity he can, as he puts it, "clear himself." However, I am of the opinion that this is not a situation that will change because of evidence, persuasion or rational argument. Press coverage of the incident, and the sub-committee's statement regarding his role in it, have made Evans a very high-profile figure, and his response is unlikely to make any significant impression on the attitude or possible reactions of the inmates to his presence in an institution. I have therefore directed you not to employ him on duties that involve working in an institution, including perimeter security.
I am sympathetic to the situation in which my direction places Mr. Evans, who was appointed as a correctional officer and wishes to continue his career as such. Regrettably his interests are not the only ones that have to be considered. I have asked you, and personally counselled him, to make every effort to provide him with or train him for alternate employment. If he is prepared to cooperate in this effort, I am confident that it will succeed.
The implication in this memorandum that the applicant may have been wrongly named in the Report of the Parliamentary Sub-Committee on the Penitentiary System as the officer who made the insulting remarks which were considered to have provoked the riot in the Millhaven Institution is reinforced by statements in letters written by the Honourable Allan Lawrence when he was Solicitor General and by the Honourable Mark Mac- Guigan, who was the Chairman of the Sub-Com mittee. In his letter to Mr. B. C. Rutherford of the Toronto Star, Mr. Lawrence said: "I can assure you that if The Correctional Service of Canada or I, as the new Solicitor General, had evidence to suggest that Mr. Evans was responsible for the riot at Millhaven in 1975,* he would no longer be employed with The Service." In his letter of March 28, 1980 to Mr. Evans, Mr. MacGuigan said: "Whether we were right or wrong in our description of the events in the Millhaven disturb ance there is no parliamentary procedure for recti fying the Report. But there are remedies in the other areas which you can invoke." At the hearing before the second Appeal Board the applicant testified that he had not made the insulting
* [This should read 1976—See Appeal Board Notes, p. 11— File: 80-21-C.S.C.-10—Ed.]
remarks in question, that he could bring several other officers, including his supervisor, who were present on the occasion to confirm this fact, that he had not been questioned or called to testify by the Parliamentary Sub-Committee, and that nowhere in the evidence before the Sub-Commit tee had it been suggested that he had made the insulting remarks.
Pursuant to the instruction given by Mr. Marsh to Mr. Weck the selection board reconvened, con sidered the memorandum from the Commissioner of Corrections to Mr. Trono, and reaffirmed its previous decision not to award the applicant any marks for "Potential for Effectiveness" on the basis of a personal appraisal report. At the hearing before the second Appeal Board Mr. Pyke, the Chairman of the selection board, testified that the members of the board as experienced officers in the penitentiary system agreed with the Commis sioner's judgment that because of the risks involved it was no longer possible to permit the applicant to work with inmates. He insisted that the members of the board had formed their own independent judgment of the applicant's suitability or potential for effectiveness as a result of having been named by the Parliamentary Sub-Committee as the person responsible for the riot. His testimo ny contains the following passages on this point:
... the board concluded that notwithstanding any other con siderations Mr. Evans was not suitable to work in an institu tional environment and did therefore not meet the requirements of the potential for effectiveness factor. (Case, Vol. 1, p. 134)
... based on the expertise again of the selection board the statements and concerns put forward by senior management were considered to be valid, applicable and realistic in leading the board to draw its own conclusions and come to a fully independent decision as to the personal suitability of Mr. Evans .... (Case, Vol. I, p. 134)
Q. No matter what evidence, from what you're saying, no matter what evidence the appellant might produce to the effect that he was not implicated at all in the riot that would have no consequence to the selection board's decision.
A. Right. If Mr. Evans was to go before a tribunal of some sort tomorrow and be found 100% innocent and get 55 apologies from someone, it would not change the context of the rationale of the decision. He has been identified, rightly or wrongly, and the fact that he could be found innocent tomorrow will not
change the opinions of the inmates. They just will not change it. It was the board's deliberations based on our knowledge of working within an institution and again, I have to state ... Mr. Done ... about personal knowledge. 1 have worked with Mr. Evans. We have worked in an institution together. I am aware of what would happen if Mr. Evans was to enter an institution. It is a valid judgment call made by the three board members that, yes, his personal safety is a factor here and it is this personal safety factor that we have to consider. (Case, Vol. I, p. 137)
And based on our judgment we cannot conceivably see Mr. Evans going in with this hanging over his head and working in an institution with inmate and fellow officers. The personal suitability and the overview was not just not there. (Case, Vol. 1, p. 139-140)
The applicant's contentions before the second Appeal Board may be summarized as follows: (1) the original selection board did not have authority to reconvene and reassess the applicant for "Poten- tial for Effectiveness"; (2) that in doing so it violated two principles of natural justice—(a) it failed to hear the applicant with reference to the new evidence considered by it, and (b) it acted as judge in its own case; (3) it improperly assessed the applicant for "Potential for Effectiveness" because it based itself entirely on the single state ment in the Surgenor memorandum, "He labours under a restriction imposed by the Commissioner of Corrections, that he is not to be employed in an institution or have contact with inmates", and ignored the rest of the memorandum which pur ported to be the personal appraisal report on the applicant; (4) Mr. Trono improperly interfered in the selection process by his direction to Mr. Weck—"The memo should now be referred to the Selection Board and the Board instructed to review Mr. Evan's application taking cognizance of the Commissioner's statement"; and (5) the selection board improperly assessed the applicant for "Potential for Effectiveness" because it relied on the opinion or judgment expressed by the Commis sioner of Corrections in his memorandum to Mr. Trono and did not make an independent assess ment.
The Appeal Board rejected the applicant's con tentions. It found sufficient authority in Mr. Marsh's letter to Mr. Weck for the selection board to reconvene and reassess the applicant for "Poten- tial for Effectiveness" in the light of the Commis-
sioner's memorandum. It held, on the authority of a decision of this Court, that the rules of natural justice did not apply to a selection board. On the question whether the selection board properly reas sessed the applicant for "Potential for Effective ness" it found that the selection board had used a "selection tool" different from the personal appraisal report that had been used for the other candidates, but it concluded that this was not a ground, in the particular circumstances, for hold ing that the applicant had been improperly assessed in respect of this factor. The Appeal Board found that the selection board had based its original assessment on the single statement in the Surgenor memorandum "He labours under a re striction imposed by the Commissioner of Correc tions, that he is not to be employed in an institu tion or have contact with inmates," and that it based its reassessment on the Commissioner's memorandum. It found in effect that the assess ment and reassessment of the applicant were not based on a personal appraisal report, for the 20 out of 70 marks attributable to that form of assess ment, but rather on the Commissioner's opinion, in which the selection board concurred, that the applicant's potential for effectiveness as a correc tional officer in an institution had been fatally impaired by the effect of the Sub-Committee's Report. On this point the Appeal Board said:
The selection board could not obtain a Performance Review and Appraisal Report (PEN 1416) for the appellant, since that form is only completed for security officers and he does not perform the duties of a security officer. Therefore, the board did not have a rating for the appellant under "Responsibilities and Skills" as a security officer and, in the absence of such a rating, it could not award him marks on that basis. On the other hand, the selection board did have the views of the Commissioner of Corrections as to why the appellant was personally unsuited for the position under competition. After carefully considering the fact that the selection board used a selection tool to partially assess the appellant against the "Potential for Effectiveness" rating factor which was different from that used to assess all other candidates, I do not find, under the circumstances, that this deviation from normal prac tice or procedures was unreasonable. I must stress that I have come to this conclusion in light of the circumstances of this particular case and that I do not wish it to be construed that I am of the opinion that a selection board can, in general, use different selection tools, at its whim, when assessing candidates. In my view, the facts of each individual case have to be considered before coming to the conclusion that the use of different selection tools for the assessment of different candi dates was proper and, in the instant case, I find that such a procedure was proper.
On the question whether the selection board was entitled to place reliance on the opinion or judg ment expressed in the Commissioner's memoran dum the Appeal Board said:
The comments of the Commissioner of Corrections in his memorandum dated February 4, 1980 may very well be catego rized as "opinion". However, I consider it reasonable for the selection board to have regarded that "opinion" as "valid evidence" upon which to base its assessment of the appellant against the "Potential for Effectiveness" rating factor, in view of the position that the person who expressed that "opinion" occupies, and the nature of his comments. Moreover, I must add that no evidence has been submitted that that "opinion" was not formed in "good faith". As a result, I cannot conclude, on the basis of the information that the selection board took into consideration, that the appellant was improperly assessed against the "Potential for Effectiveness" rating factor.
The applicant's contention on this section 28 application is in essence that in its reassessment of him in respect of the factor "Potential for Effec tiveness" the selection board failed to act in accordance with the merit principle and to treat him with the essential fairness that is necessarily related to that principle, and that accordingly the Appeal Board erred in law in failing to allow the applicant's appeal.
The applicant contends that he was entitled to be assessed or reassessed in respect of the factor "Potential for Effectiveness" on the basis of a personal appraisal report, as in the case of the other candidates, rather than on the basis of the Commissioner's opinion as to whether he could be employed in an institution as a correctional officer as a result of the publicity given to the allegation or finding that he had been responsible for the riot in the Millhaven Institution in 1976. In support of this contention counsel for the applicant submitted that it was the duty of the selection board to assess the qualifications of the applicant for the position and not to decide whether for some other reason he should not or could not be appointed to the posi tion. The assessment of qualifications is for the selection board; the question whether a person who is otherwise qualified should not, for special rea sons, be appointed to a particular position is for the Public Service Commission. By the manner in which it acted the selection board deprived the applicant of a true assessment of his qualifications for the position of Senior Correctional Officer. It assessed his "Potential for Effectiveness" on a different basis than that of the other candidates
and thus departed from or contravened the merit principle.
According to the testimony before the Appeal Board the selection board requested the most recent personal appraisal report on the candidates. It was stated, without challenge, at the hearing of the section 28 application that the last personal appraisal report of the applicant as a Correctional Officer (CX-COF-2) was one made in 1977, some two years before the selection process. In 1977 the applicant was removed from the Millhaven Institu tion and assigned, on the direction of the Commis sioner to the duties of a "security officer" in Regional Headquarters. The memorandum of August 16, 1979 of Mr. Surgenor, although en titled "Performance Review & Appraisal" makes it clear that no one in the Division in which the applicant had bccn employed since his re-assign ment in 1977 was qualified to submit a "Perfor- mance Review & Appraisal Report" on him as a Correctional Officer (CX-COF-2), and I infer from the memorandum and the testimony before the Appeal Board that it was not considered possi ble, because of the extent to which the applicant was able or willing to perform the duties of a "security officer" in Regional Headquarters, to submit a "Performance Review & Appraisal Report" on the applicant as a "security officer" in the form approved for the Correctional Service of Canada and apparently attached to Mr. Surgen- or's memorandum. It is clear from the evidence and was found as a fact by the Appeal Board that the selection board did not base its assessment of the applicant in respect of the factor "Potential for Effectiveness" on anything that was said in Mr. Surgenor's memorandum apart from the single statement, "He labours under a restriction imposed by the Commissioner of Corrections, that he is not to be employed in an institution or have contact with inmates."
The contention of the applicant on this issue before the first Appeal Board was summarized by the first Appeal Board as follows: "The Rating Board, consequently, should have obtained a proper appraisal from someone who had supervised the appellant at the CX 2 level or, if this was not possible, the Board should have based the appel lant's assessment on `Potential for Effectiveness' solely on the results of his interview." The first
Appeal Board did not express an opinion as to whether the Surgenor memorandum met the requirements of a personal appraisal report, appar ently because the selection board had not based itself on the memorandum as a whole but only on the single statement that has been quoted concern ing the restriction placed on the applicant's employment. But the first Appeal Board did hold that the selection board could validly base its assessment of "Potential for Effectiveness" on this restriction if it found, upon proper investigation, that there was "valid evidence that it was related to `Potential for Effectiveness'." As the first Appeal Board put it, "If the Rating Board had investigated the reasons for the restriction placed on appellant Evans' work activities and had dis covered valid evidence that Mr. Evans was person ally unsuited for working with inmates then I would not fault the Board for concluding that appellant Evans lacked `Potential for Effective ness' ". The fault that the first Appeal Board found with the selection board was not that it had based itself on the restriction rather than on an appraisal report, but that it had failed to investi gate and make an independent assessment of the reason for the restriction.
In so far as the selection board was required, or justified, to act in accordance with the reasons of the first Appeal Board in carrying out the reassess ment of the applicant in respect of "Potential for Effectiveness" that it was instructed by the Com mission to make, I do not think it was required to base itself on a personal appraisal report in the usual form, but it could rely on the Commission er's restriction, if judged to be well founded, as an overriding or peremptory factor that precluded a passing mark for "Potential for Effectiveness". I do not see how, in the face of this restriction and the opinion on which it was based, if judged by the selection board to be well founded, that the board could assess the applicant as meeting the minimum requirements for "Potential for Effectiveness". The duty of the selection board was to make an overall assessment of "Potential for Effectiveness", involving, in the words of the statement of qualifi cations for the position, an "Overview of total suitability", and not to determine what the appli cant's "Potential for Effectiveness" might have
been had it not been impaired for the reasons given by the Commissioner. The opinion of the Commis sioner was clearly related to effectiveness. It was not a reason for not appointing the applicant unrelated to the qualifications to be assessed by the selection board. Indeed, as contended by coun sel for the respondent, it was related not only to the specific factor "Potential for Effectiveness" but also to the basic qualification of "capability to satisfactorily perform Correctional Officer duties in a minimum, medium or maximum security institution." The essential fact on which the Com missioner's opinion was based, namely, publicity given to the finding or statement in the Report of the Parliamentary Sub-Committee that the appli cant was responsible for the insulting remarks that provoked the disturbance in the Millhaven Institu tion was before the selection board. Although an inquiry by the selection board into the truth of the Sub-Committee's statement might have gone some way to satisfy the understandable desire of the applicant for justice, I do not think it was the duty or function of the selection board to make such an inquiry. It was not a tribunal equipped to make such an inquiry. What was in issue, as indicated by the Commissioner's opinion, with which the mem bers of the selection board concurred on the basis of their own experience in the penitentiary system, was the likely effect of the statement, with the publicity given to it, on the attitude of inmates, regardless of any subsequent attempt to establish and communicate a different view of the facts. This was no doubt an opinion or judgment, but it was one based on fact and experience, not essen tially different from other aspects of personal appraisal. It had some foundation. That is the sense, I think, that should be given to the require ment of "valid evidence" in the reasons of the first Appeal Board.
This is a disturbing case because there is a strong suggestion in the evidence that the appli cant may have suffered an injustice, and that he has sought in vain for a forum in which to have it remedied. It is the opinion of the Commissioner
and the selection board that because of the way inmates think and behave it cannot be remedied, at least in so far as the applicant's ability to work with inmates is concerned. One is reluctant to accept that conclusion, but it is the judgment of persons of experience in the penitentiary system. Neither the Appeal Board nor the Court can sub stitute its judgment on this issue for theirs.
In the result, I agree with the Appeal Board that the selection board did not fail to act in accord ance with the merit principle when in the very special circumstances of this case it based its overall assessment of the applicant's "Potential for Effectiveness" on the Commissioner's judgment, with which it agreed, as to the likely effect of the public perception of the applicant's responsibility for the disturbance in the Millhaven Institution in 1976. It was an assessment that was different than that applied to other candidates because it was one that was peculiar to the case of the applicant. It could not be ignored by the selection board. To have done so would have been to have failed to act in accordance with the merit principle and to conclude on some other basis, not related to all the pertinent facts, that there was potential for effec tiveness, when there was reason to believe that it did not exist. The restriction placed by the Com missioner came to the attention of the selection board at a particular stage of the selection proc- ess—in response to the request for a personal appraisal report—but that does not mean that the restriction had a bearing only on that stage of the assessment. It had a bearing on the entire question of potential for effectiveness or suitability.
The essential submission of the applicant on the question of fairness is that the selection board failed to offer the applicant an opportunity to be heard with respect to the Commissioner's memo randum on which it based its reassessment. Coun sel for the applicant conceded that the selection board was not exercising a judicial or quasi-judi cial function subject to the rules of natural justice, but he invoked the doctrine of fairness that was recognized by the Supreme Court of Canada in Nicholson v. Haldimand-Norfolk Regional Board of Commissioners of Police [1979] 1 S.C.R. 311. In my opinion a selection board is not obliged to hear candidates in a competition in so far as that
implies a right to present evidence and submit arguments concerning disputed questions of fact or law. It is like any examining body. Its task is to set the examination or evaluative process, to carry it out and to determine the results. It is not obliged, for example, to offer candidates an opportunity to be heard on the merits of a personal appraisal report. Internal administrative procedures may provide for review of personal appraisal reports, but that is not the function of a selection board which must take a report as it finds it. The Com missioner's memorandum with respect to employ ment of the applicant was in my opinion in the same category.
For these reasons I would dismiss the section 28 application.
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RYAN J. concurred.
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KERR D.J. concurred.
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