Judgments

Decision Information

Decision Content

T-1705-84
Robert Gould (Applicant) v.
Attorney General of Canada, Chief Electoral Offi cer of Canada, and Solicitor General of Canada (Respondents)
Trial Division, Reed J.—Ottawa, August 28 and 29, 1984.
Constitutional law — Charter of Rights — Voting rights — Application for interlocutory mandatory injunction enabling prison inmate to vote in federal election — Inmate seeking declaration Act s. 14(4)(e) contrary to Charter s. 3 — S. 3 clearly entitling applicant to relief — Evidence not establish ing reasonable, demonstrably justified limit — Security con siderations not justifying denial of right to vote — S. 14(4)(e) not limited to security-risk prisoners — Right to vote com prising more than casting ballot — Right to vote distinct from Charter freedoms — Inability to participate in full electoral process not justifying denial of all rights — Denial of consti tutional right grave injustice — Canada Elections Act, R.S.C. 1970 (1st Supp.), c. 14, s. 14(4)(e) — Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.), ss. I, 3, 24(1).
Penitentiaries — Prisoners' rights — Application for inter locutory injunction enabling inmate to vote in federal election
— Seeking declaration Act s. 14(4)(e) contrary to Charter s. 3
— S. 3 clearly entitling applicant to relief — Evidence not establishing reasonable, demonstrably justified limit — Secu rity considerations not justifying denial of right to vote — S. 14(4)(e) not limited to security-risk prisoners — Inability to participate in full electoral process not justifying denial of all rights — Loss of applicant's constitutional right greatly out weighing burden imposed upon respondents — Simple voting procedure can be arranged before election day, though not if many inmates involved — Canada Elections Act, R.S.C. 1970 (1st Supp.), c. 14, s. 14(4)(e) — Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.), ss. I, 3.
Judicial review — Equitable remedies — Injunctions — Application for interlocutory mandatory injunction enabling prison inmate to vote in federal election — Inmate seeking declaration Act s. 14(4)(e) contrary to Charter s. 3 — Issues same as on other interlocutory applications — Applicant meeting requirement of serious question to be tried — Also strong prima facie case — Balance of convenience completely
in applicant's favour — Preservation of status quo unimpor tant where very strong case and balance heavily for applicant — Status quo incorporating law as existed at date of claim — No undue delay in commencing proceedings — Respondents not caught unprepared — Applicant not avoiding burden of proof — Interlocutory injunction based on non final decision and not inappropriate — Interlocutory injunction often in practice deciding issue — That validity of legislation in issue not precluding injunction — No rewriting of law — Relief granted under general jurisdiction regarding mandatory injunctions — Canada Elections Act, R.S.C. 1970 (1st Supp.), c. 14, s. 14(4)(e) — Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.), ss. 1, 3.
Elections — Voting rights — Application for interlocutory injunction enabling prison inmate to vote in federal election — Inmate suing for declaration Elections Act s. 14(4)(e) contrary to Charter s. 3 — S. 3 clearly entitling applicant to relief No reasonable, demonstrably justified limit — Right to vote comprising more than casting ballot — Inability to participate in full electoral process not justifying denial of all rights — Canada Elections Act, R.S.C. 1970 (1st Supp.), c. 14, s. 14(4)(e) — Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.), ss. 1, 3.
Paragraph 14(4)(e) of the Canada Elections Act purported to prohibit inmates of penal institutions from voting at elec tions. The applicant, having been convicted of a criminal offence, was a prisoner in a federal institution. With a federal general election scheduled to occur, he commenced an action in the Trial Division, seeking a declaration that paragraph 14(4)(e) was contrary to section 3 of the Charter—which declares the right of every Canadian citizen to vote—and so was invalid.
The instant proceeding was an interlocutory motion for a mandatory injunction enabling the applicant to vote in the upcoming election. It was anticipated that the applicant would be released a few months after the election.
Held, the motion is granted.
The issues on this motion are the same as those which must be considered in ruling upon any other request for interlocutory relief.
With respect to the strength of the applicant's case, the applicable requirement is the one stated in the American Cyanamid case: namely, that there exist a serious question to be tried. This condition has certainly been met. Indeed, the applicant has probably established even a strong prima facie case. By virtue of section 3, he has a constitutionally protected
right to vote and thus, at least at first sight, a very clear entitlement to the relief which he claims.
Section 1 of the Charter does allow for the imposition of reasonable, demonstrably justified limits on the applicant's right; however, the evidence adduced did not significantly weaken the applicant's prima facie case. In the first place, it is difficult to accept security considerations as a justification for denying inmates the right to vote. Experience in other jurisdic- tions establishes that voting by inmates is workable, from both a security and an administrative point of view. Moreover, paragraph 14(4)(e) denies the vote not just to those prisoners who are security risks or are prone to violence, but rather to all prisoners.
Nor is there a basis for upholding the paragraph in the argument that the security requirements of a penal institution would prevent some inmates from participating in parts of the electoral process other than the actual voting. It is generally true that the right to vote guaranteed by section 3 comprises more than the right to cast a ballot. Nonetheless, it would appear that the right to vote was seen by the authors of the Charter as being distinct from various freedoms set forth elsewhere therein. Consequently, the need to curtail some of a prisoner's rights does not imply that the denial of all of them is justified.
While the Court has before it an affidavit stating that the deponent has examined the concept of inmate voting over a period of four years, and that expert evidence bearing upon the reasonableness of the paragraph 14(4)(e) limitation might possibly be led, the assertions in this affidavit were of a tentative nature. There was also evidence that limitations on the right of prisoners to vote exist in many countries, but that evidence is not necessarily supportive of the view that such a limitation is reasonable and demonstrably justified. Limitations of this kind may instead be simply an outdated remnant of an earlier period.
As for the balance of convenience, it is completely in the applicant's favour. He stands to lose what is, at least prima facie, a constitutionally guaranteed right, while the respondents have virtually nothing to lose, inasmuch as the granting of the injunction would make only a small demand upon them. Had the claim been brought on behalf of a great number of inmates, the balance of convenience might have tipped towards the other side, since it would have been impossible to set up the necessary voting machinery before election day. That fact, however, should not affect the claim of this applicant. It is possible to devise a simple procedure whereby the applicant may vote, and the necessary arrangements may be made in advance of elec tion day without difficulty. Granting him the injunction would not enable other inmates to vote, but no unfairness is thereby worked upon the others. The applicant should not be denied relief because he chose to assert his claim when others did not do likewise.
It seems that when an applicant's case is a very strong one and the balance of convenience is heavily in his favour, the objective of preserving the status quo is not an important factor
in the decision as to whether an interlocutory injunction should be granted. Even if this is incorrect, though, in this case the status quo must be taken to incorporate the law as it existed at the date of the claim—i.e., it must be taken to encompass section 3 of the Charter. That provision elevated the right to vote above rights found in ordinary legislation. Also, the Chart er was intended to make, and did make, substantive changes in some areas.
The applicant was not guilty of any undue delay in com mencing proceedings. The respondents argued that the appli cant should have launched an action for a declaration two years ago, thus allowing the courts to make a final determination regarding his rights under the Charter and the Elections Act, rather than waiting until the eve of an election and seeking interlocutory relief—which form of relief is, according to the respondents, inappropriate in this case. However, the respond ents as well could have initiated proceedings within the last two years to obtain clarification of the issue. Given the statement that the question of inmate voting has been under active policy consideration for four years, it is difficult to accept that the respondents were caught unprepared by the applicant's claim, or that an enormous burden was imposed upon them by virtue of their being required to provide evidence on fairly short notice. There is no evidence that the applicant was trying to avoid the onus of proof which he would have to discharge in order to obtain a final remedy. Certainly, a final decision upon the validity of paragraph 14(4)(e) can be arrived at only via the normal trial process; however, this does not mean that the present case is one in which an interlocutory injunction, which will be based upon a non-final decision, is necessarily inappropriate.
The respondents objected that granting the injunction would, as a practical matter, settle the issue in this case finally; but an interlocutory injunction often has this effect, and such a pros pect is not a valid reason for refusing an injunction.
Where the question is the validity of legislation, consider ations pertaining to the balance of convenience will often rule out an injunction. This, however, is a case in which the balance is completely in the applicant's favour. Furthermore, the denial of a constitutionally guaranteed right is a grave injustice, and so must be prevented.
Granting the interlocutory injunction does not amount to a rewriting of the law. The decision of the Court will operate only as between the parties, and does not determine the broader issue of the validity of paragraph 14(4)(e). In any event, both paragraph 14(4)(e) and section 3 are law, and to choose one over the other is not to rewrite the law.
The relief requested herein may be granted pursuant to the Court's general jurisdiction in respect of mandatory injunc tions. It is therefore unnecessary to decide whether section 24 of the Charter is applicable where an interlocutory remedy is sought.
CASES JUDICIALLY CONSIDERED
APPLIED:
American Cyanamid Co. v. Ethicon Ltd., [1975] A.C. 396 (H.L.).
CONSIDERED:
Re Jolivet, et al. (1983), 7 C.C.C. (3d) 431 (B.C.S.C.); Morgentaler et al. v. Ackroyd et al. (1983), 42 O.R. (2d) 659 (H.C.).
COUNSEL:
Fergus J. O'Connor for applicant.
Duff F. Friesen, Q.C. and Seymour Mender for respondents Attorney General of Canada and Solicitor General of Canada.
E. A. Ayers for respondent Chief Electoral Officer of Canada.
SOLICITORS:
Correctional Law Project, Faculty of Law, Queen's University, Kingston, Ontario, for applicant.
Deputy Attorney General of Canada for respondents Attorney General of Canada and Solicitor General of Canada.
Borden & Elliot, Toronto, for respondent Chief Electoral Officer of Canada.
The following are the reasons for order ren dered in English by
REED J.: This is a motion for an interlocutory injunction, mandatory in nature, requiring the Chief Electoral Officer and the Solicitor General (or their subordinates) to enable the applicant to exercise his right to vote in the September 4, 1984, federal election. The motion is brought pursuant to an order of the Associate Chief Justice, dated August 22, 1984, which dismissed an application by way of motion for an order of mandamus. The Associate Chief Justice's order was based on the fact that the applicant, in proceeding by way of motion, had chosen the wrong procedural route. The order expressly noted that it was without prejudice to the right of the applicant to reframe his claim: to proceed by way of statement of claim and move for interlocutory relief within the con text of such action.
The applicant's claim is that section 3 of the Canadian Charter of Rights and Freedoms [being Part I of the Constitution Act, 1982, Schedule B,. Canada Act 1982, 1982, c. 11 (U.K.)] accords him a constitutional right to vote:
Democratic Rights
3. Every citizen of Canada has the right to vote in an election of members of the House of Commons ....
He claims that his right to vote is being infringed by the application of paragraph 14(4)(e) of the Canada Elections Act [R.S.C. 1970 (1st Supp.), c. 14]:
14....
(4) The following persons are not qualified to vote at an election, and shall not vote at an election:
(e) every person undergoing punishment as an inmate in any penal institution for the commission of any offence;
The applicant, having been convicted of a crimi nal offence, is a prisoner in a federal institution, Joyceville Penitentiary, near Kingston, Ontario. In the normal course of things he anticipates being released in January, 1985. He considers Ancaster, Ontario, his home. At his request, his name was given to the enumerators and placed on the list of electors for the electoral district of Hamilton- Wentworth.
The issues to consider, as with all requests for interlocutory relief, are: (1) the strength of the applicant's case; (2) the balance of convenience; (3) the maintenance of the status quo; and (4) the conduct of the parties.
Strength of applicant's case
It is clear that Canadian law has now accepted the American Cyanamid' test as that applicable in requests for interlocutory injunctions:
The court no doubt must be satisfied that the claim is not frivolous or vexatious; in other words, that there is a serious question to be tried.
In this case even if the test set out in some of the earlier jurisprudence (the requirement of a strong prima facie case) were still applicable I think the applicant would have met it. But, he certainly has met the test of "a serious question to be tried."
The applicant, as a Canadian citizen, is clearly given a constitutionally protected right to vote by
' American Cyanamid Co. v. Ethicon Ltd., [1975] A.C. 396 (H.L.) at p. 407.
section 3 of the Charter. Prima facie, he has a very clear right to the claim he asserts.
Is the strength of his case weakened, then, because limitations on that right can be imposed? Section 1 of the Charter allows limitations which constitute:
1. ... reasonable limits prescribed by law ... demonstrably justified in a free and democratic society.
The evidence before me was not of such a nature that I could characterize it as weakening in a significant way the applicant's prima facie case. I will review that evidence.
An affidavit in support of the respondents' posi tion stated:
I believe, as a result of my experience in security matters affecting the CPS, that allowing every inmate to vote would constitute a threat to good order, security and administration of the federal penal institutions.
It is hard to accept that security reasons could constitute justification for denying inmates the right to vote. The fact that other jurisdictions, for example, Quebec, are able to provide such mech anisms demonstrates that it is not unworkable, either from an administrative or security point of view. (I note that some jurisdictions deny the right to vote on a selective basis, either when it is expressly made part of the judge's sentence or in relation only to certain very specific offences such as election offences.) Also, paragraph 14(4)(e) does not simply deny the vote to prisoners who are security risks or prone to violence;- it is all-inclu sive. Consequently, it is hard to characterize paragraph 14(4)(e) as "a reasonable limit . .. demonstrably justified" on the ground that it is necessary for security reasons.
The affidavit also states:
Due to the security requirements [of the penal institutions] I am of the opinion that the inmate population's ability to assemble and to receive and exchange information with candi dates and their peers would be limited to the extent that some inmates could have to exercise the right to vote in the absence of any real opportunity to truly participate in the rest of the electoral process.
In this regard the decision of the British Columbia Supreme Court in Re Jolivet, et al. (1983), 7 C.C.C. (3d) 431 (B.C.S.C.), was relied upon. In that decision it was held that the right to vote as guaranteed by section 3 of the Charter means more than the right to cast a ballot. The Court held (at pages 434-435):
It means the right to make an informed electoral choice reached through freedom of belief, conscience, opinion expres sion, association and assembly—that is to say with complete freedom of access to the process of "discussion and the inter play of ideas" by which public opinion is formed. Denial by the State of the freedoms necessary for the making of a free and democratic electoral choice involves denial also of the sort of right to vote contemplated by the Charter.
While I accept that this is generally so, the right to vote and the right to freedom of association, belief, conscience and expression, etc. are found in separate sections of the Charter. It would appear that they were thought of as being distinct rights. Consequently I do not think that because some of a prisoner's rights must necessarily be curtailed (e.g.: the freedom of association, of expression, the right to be a candidate for election) this justifies curtailing the whole spectrum. It seems to me there is a logical fallacy somewhere in that argument.
Another affidavit filed in support of the respondents' position states:
THAT I am employed as a senior policy analyst in the Criminal Justice Policy Directorate of the Policy Branch of the Ministry Secretariat of the Department of the Solicitor General, and, as such, am responsible for providing policy advice to the Deputy Solicitor General on criminal justice issues.
THAT I have been in this position for the past four years, during which time, I have examined in depth the concept of inmate voting.
THAT I further believe that there are experts in the field of criminology and law who have conducted studies on the desira bility of retaining the type of sanction imposed by section 14(4)(e) of the Canada Elections Act, and given time to contact these experts, the Crown might be able to lead evidence which would be of benefit to the court in determining whether or not section 14(4)(e) of the said Act is a reasonable limita tion .... [Underlining added.]
I was struck by the tentative nature of these assertions. I could not conclude that they signifi cantly weaken the applicant's case.
One last argument in this regard needs to be considered. The affidavit material demonstrates that limitations on the right to vote of prisoners exist in many countries. I could not conclude, however, that this was, by itself, evidence of a "reasonable limit ... demonstrably justified". It may be no more than a vestige of that period in our history when a convicted person lost all legal status—it may be no more than a remnant of that historical situation. (I note that some of these countries still deny the vote to undischarged bankrupts.)
Balance of Convenience
It seems clear that the balance of convenience is all in the applicant's favour in this case. His claim relates only to his right to vote. He is not claiming on behalf of all inmates. Counsel for the respond ents argued that it was somehow unfair to grant him the relief sought because it gave him a right denied to all other inmates. I do not think so: the applicant chose to press his case, so to speak; others did not. There may be many people who are left off the voters' list who never complain or whose names are on the voters' list but they are not concerned enough to exercise their democratic right. I do not think Mr. Gould's claim should be rejected because he chose to assert his claim while others did not.
I recognize that had the claim been on behalf of a great many inmates the balance of convenience might have tipped in the other direction because it would simply be impossible to set up the ma chinery before September 4 for providing all inmates (or a large number) with the right to vote. But, I do not think that consideration should affect Mr. Gould's claim. The affidavit filed by Mr. Hamel, the Chief Electoral Officer, makes it very clear that it was entirely possible to take the necessary steps to meet Mr. Gould's claim before September 4, with no difficulty. In colloquial terms the respondents have virtually "nothing to lose" by an order granting the applicant the remedy.
Allowing Mr. Gould to vote would not require that he be escorted by security officers to the polling booth in Hamilton-Wentworth, as was argued before me. A simple procedure can be devised for either allowing Mr. Gould to vote by proxy (as his counsel suggested) or by collecting a ballot from him perhaps in advance of election day, and having it transmitted to the appropriate poll. 2
In considering then, the balance of convenience, little obligation would be imposed on the respond ents (less than is often the case in interlocutory injunctions not characterized as of a mandatory nature) while the loss to the applicant would be the denial of at least a prima facie constitutionally guaranteed right.
Status Quo—Conduct of the Parties
It remains to consider some arguments of the respondents which might be described as relating to the preservation of the status quo and the conduct of the parties.
My reading of the jurisprudence does not lead me to believe that the "preservation of the status quo" is an element that weighs heavily when the strength of the applicant's case and the balance of convenience are heavily in favour of the applicant. In any event, even if it does, I think that in this case the status quo must be assessed in the light of the law as it exists at the date of the applicant's claim—that is, in the light of the existence of section 3 of the Charter of Rights. I do not think the status quo should be determined by reference to the situation which existed prior to the enact ment of that legislation. Counsel for the respond ents argues that the right to vote is not a new right, that it has always existed and, therefore, there is no change of the status quo by the Chart er. This may be so in many instances and in general terms but prior to the enactment of the Charter there was no constitutionally guaranteed right of citizens to vote; there was no elevation (so to speak) of that right above others found in
2 The mechanism agreed upon by counsel for the Chief Electoral Officer and by counsel for the applicant was to require the returning officer in the electoral district of Hamil- ton-Wentworth to accept a proxy vote from Mrs. Thea Misen- er, the applicant's one-time guardian.
ordinary legislation. Also the Charter did and was intended to make changes in some areas.
Another argument made is that the applicant unduly delayed in seeking a declaration as to his rights, that he could have started a declaratory action two years ago to have the issue finally determined by the courts but that he chose not to do so but to wait until the eve of an election and seek interlocutory relief. (As noted above the inter locutory relief was sought because of procedural barriers not because the applicant was attempting to avoid an examination of the issue by way of final decision.) Part of the respondents' argument on this point is that the instant case is inappropri ate for an interlocutory injunction because a deci sion as to whether paragraph 14(4)(e) of the Elec tions Act is a demonstrably justifiable limitation on the right to vote, is one that can only be made after hearing lengthy evidence and careful con sideration. I agree that a final determination of the issue must proceed on that basis. But this decision in this case is not a final decision respecting that issue—it is based only on the conclusion that the applicant has demonstrated a prima facie case. I note also that the affidavit filed in support of the respondents' position indicates that the question of inmate voting has been under active policy con sideration by the respondents for four years. I find it hard therefore to accept the argument that the applicant's claim caught the respondents in an unprepared state or that it creates an enormous burden on the respondents by putting them in a position of having to bring forward, on fairly short notice, evidence respecting the limitation on voting rights. I was particularly struck by the fact that the aforementioned affidavit indicated that the issue had been under study for four years yet the conclusions it was able to come to respecting a justification for the limitation on voting rights were very tentative.
There is no doubt that the question of whether or not paragraph 14(4)(e) is a demonstrably jus tifiable limitation is one that will have to be finally determined in the normal trial process but I do not
think the applicant should be denied his remedy because he did not start a declaratory action to have the issue clarified some time within the previ ous two years. The respondents, equally, could have moved within that two-year time period for clarification from the courts as to the interpreta tion of section 3 of the Charter and paragraph 14(4)(e) of the Canada Elections Act. There is no evidence that the applicant delayed unduly or that the applicant was trying to avoid the burden of proof that would rest on him where a remedy of a final nature is sought. If there were, it would clearly be a case in which an interlocutory injunc tion should be denied.
The respondents also argued that an interlocuto ry injunction was not available in this case because of what I will call "the nature of the case". These arguments were generally that an injunction was not appropriate because: (1) an interlocutory injunction would determine the matter—it not being likely that the applicant would pursue his claim for declaratory relief; (2) the validity of federal legislation was in issue; and (3) giving a remedy would involve the Court in rewriting the law.
With respect to the first case, it is often the nature of interlocutory injunctions that as a practi- cal•matter, they finally determine the issue in the case. My reading of the jurisprudence has not led me to the conclusion that this is a reason for a court to back away from granting one where it considers it just to do so. With respect to the second point I was not referred to any case which said that interlocutory injunctions should not be granted where the validity of legislation was in issue. Counsel for the respondents referred me to Morgentaler et al. v. Ackroyd et al. (1983), 42 O.R. (2d) 659, where Mr. Justice Linden of the Ontario High Court said [at page 6681:
... the balance of convenience normally dictates that those who challenge the constitutional validity of laws must obey those laws pending the court's decision .... This does not mean, however, that in exceptional circumstances this court is pre cluded from granting an interim injunction to prevent grave injustice, but that will be rare indeed.
I agree that balance-of-convenience consider ations, often, probably normally, will dictate that interlocutory injunctions are inappropriate where the issue is the validity of legislation. But, as noted above, in this case that is not so. The balance of convenience is all on the applicant's side. There will probably be few instances, when the attack on the constitutionality of a statute is concerned, in which this will be so. But this is one. Accordingly, I do not think I have to decide whether the denial of the right to vote is a "grave injustice" or not. But, if I had to so decide, I would hold that the denial of a constitutionally guaranteed democratic right is a grave injustice.
Nor have I accepted the respondents' argument that in this case to give the applicant a remedy is to rewrite the law.
A decision in this case only operates as between the parties; it does not determine the broader fundamental question as to the status of paragraph 14(4)(e) of the Elections Act in relation to section 3 of the Charter. That question undoubtedly needs to be determined and I would assume it will be, prior to any subsequent federal election (perhaps by way of reference). In any event an order of the nature sought by the applicant is not a rewriting of the law. The law exists in section 3 of the Charter. The choice for the Court is either to apply the Charter or to apply the Canada Elections Act. Both are equally law and in choosing one over the other there is no more rewriting of the law than if the "other" was chosen over the "one".
Section 24 of the Charter was cited to me as applicable:
24. (1) Anyone whose rights or freedoms, as guaranteed by this Charter, have been infringed or denied may apply to a court of competent jurisdiction to obtain such remedy as the court considers appropriate and just in the circumstances.
Given the time available for making a decision in this case, a thorough argument as to whether the section was applicable in the case of interlocu tory relief was not heard. It may very well be, on a careful examination of the principles involved. But, counsel for the respondents argues it is not, coun-
sel for the applicant argues it is. In any event, I make no finding on that point since I think it is within the Court's jurisdiction to make the order claimed as part of its general jurisdiction with respect to mandatory injunctions. An order in this case to the returning officer requiring him (her) to accept a proxy vote is not unlike other mandatory orders either to public officials or private individu als to either perform or cease performing some act. I note that in the Ackroyd case (supra) the Court did not feel it needed to rely on section 24 for jurisdiction, although it did not deal with that issue.
For all the above reasons I think this is an appropriate case in which I should exercise my discretion to grant the relief claimed by the appli cant. An order will issue accordingly.
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.