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Trustees Of The Roman Catholic Separate Schools For Ottawa v. Ottawa Corporation And Others

Privy Council
Nov 2, 1916
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Structured Summary of the Opinion (Lord Buckmaster, L.C.)

Factual and Procedural Background

These consolidated appeals raised the question whether Section 3 of the Ontario statute 5 Geo. V, c. 45 (1915) was valid and within the competency of the provincial Legislature. The appellants contended that Section 3 prejudicially affected rights and privileges reserved under provision 1 of Section 93 of the British North America Act, 1867, in respect of denominational (Roman Catholic separate) schools.

The Act's preamble recited an action then pending in the Supreme Court of Ontario between R. Mackell and others and the appellants; that action was ultimately decided against the appellants. The preamble further recited that the appellants had failed to open the schools at the appointed time, had failed to provide or pay qualified teachers, and had threatened to close the schools and dismiss teachers. Counsel for the appellants did not question the accuracy of these recitals for the purposes of the appeal.

Section 1 of the 1915 Act was not in issue; Section 2 declared the duties of the appellants. Section 3 authorized the Minister of Education, with the approval of the Lieutenant-Governor in Council, on his opinion that the board failed to comply with the Act, to appoint a Commission (3–7 persons), to vest in that Commission all or any of the board’s statutory or other powers (including rights, properties and assets), to suspend or withdraw all or any part of the board's rights, powers and privileges and restore them at discretion, and to direct disposition of legislative grants.

Acting on the Minister's opinion, a Commission (the respondent Commission) was appointed by Order in Council dated 25 July 1915. The present appeals challenge the validity of Section 3 on constitutional grounds.

Legal Issues Presented

  1. Whether Section 3 of 5 Geo. V, c. 45 (1915) Ontario is valid and within the competency of the provincial Legislature, or whether it is ultra vires because it prejudicially affects rights and privileges reserved by provision 1 of Section 93 of the British North America Act, 1867.
  2. Whether the appellant board (elected trustees for Roman Catholic separate schools in the City of Ottawa) falls within the class of persons protected by provision 1 of Section 93, such that the powers in Section 3 would operate prejudicially against rights or privileges existing in the province at the Union.

Arguments of the Parties

Appellants' Arguments

  • Section 3 prejudicially affects rights and privileges with respect to denominational schools reserved under provision 1 of Section 93, British North America Act 1867.

Respondent Commission's Arguments

  • The appellant board does not come within the category of "a class of persons" protected by provision 1; thus no right or privilege with respect to denominational schools existing at the Union has been prejudicially affected.
  • The protection in provision 1 attaches to rights or privileges possessed by all adherents of Roman Catholic schools in the Province, whereas the appellant board represents only a minority (a section) of that larger class.
  • Practical difficulties were stressed: that the Commission pressed the Court to consider the lack of an adequate alternative means to ensure the proper education of Roman Catholic children in the City of Ottawa if the appellant board failed in its duties.
  • It was argued that no evidence had been called by the appellants to show that withdrawal of rights operated to their prejudice.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Appellant board v. R. Mackell and others — (A.I.R. 1916 P.C. 185; 1917 A.C. 62; 86 L.J. P.C. 65) Recent consideration of Section 93 of the British North America Act; the effect of Sections 91 and 92 and the exclusivity of provincial jurisdiction over education subject to specified provisions. The Court relied on this authority to confirm that provincial Legislatures have exclusive jurisdiction over education, subject to the specific protections in Section 93(1), and that rights or privileges reserved by provision 1 cannot be prejudicially affected except by Imperial legislation.
Judgment of Meredith, C.J.O. (36 Ont. L.R. at p. 491) Historical and doctrinal background summarizing the basis of the Roman Catholic claim to Separate Schools and the injustice perceived when Catholic parents were compelled to support schools contrary to conscience. The opinion cited Meredith, C.J.O.'s summary to frame the historical context of separate schools and to illustrate why the protection in Section 93(1) had been reserved; the Court used this to contextualize the constitutional protection at issue.

Court's Reasoning and Analysis

The Court examined the language and practical effect of Section 3, particularly subsections (b) and (c), and reasoned as follows:

  1. The powers in Subsections 3(b) and 3(c) are expressed in very wide terms: the Minister, with the approval of the Lieutenant-Governor in Council, may suspend or withdraw all or any part of the rights, powers and privileges of the appellant board, without limitation in time, and may vest those rights in a Commission nominated by the executive. The withdrawal may be for an indefinite time and restoration is discretionary.
  2. The Court analyzed whether the appellant board fell within the class protected by provision 1 of Section 93. The Court examined the Separate Schools Act, 1863 (26 Vict. c. 5), noting that Section 2 of that Act conferred the right to elect trustees for management of a separate school on supporters of a separate school within a local area (any number not less than five, being heads of families, freeholders and householders who are Roman Catholics) — i.e., on supporters within the designated local area.
  3. On that statutory basis the appellant board were the elected trustees for Roman Catholic separate schools within the City of Ottawa and thus represented a section of the class of persons protected by Section 93(1). The Court found no limiting words or contextual implication in provision 1 to exclude such a board from the benefit of the provision.
  4. Because the appellant board represent persons within the protection of provision 1, Section 3’s grant of authority to withdraw their legal rights and privileges in toto for an indefinite period necessarily operates to the prejudice of that class of persons. The Court emphasized that it was the creation of such a power — regardless of any present or future exercise — that rendered the provision objectionable under Section 93(1).
  5. The Court rejected the argument that absence of evidence showing actual prejudice required dismissal. It held that no such evidence was necessary in light of the enabling provision which permitted complete and indefinite withdrawal of rights — an outcome that, by its nature, prejudicially affected the protected class.
  6. The Court acknowledged the practical considerations pressed by the respondent Commission — the difficulty of ensuring continued education for Roman Catholic children if the board failed in its duties — but observed that the decision did not affect the overarching principle of compulsory free primary education established under the School Law of 1850. Moreover, if the board and supporters fail to perform duties incident to their rights, children of Roman Catholic parents would be obliged to attend common schools and lose the reserved privileges.
  7. Concluding the analysis as a question of statutory construction and constitutional competence, the Court determined that Section 3 was inconsistent with the protection in Section 93(1) and therefore was ultra vires the provincial Legislature.

Holding and Implications

Holding: The appeals are allowed and Section 3 of 5 Geo. V, c. 45 (1915) Ontario is declared ultra vires.

Implications and direct consequences described in the opinion:

  • The Act (specifically Section 3) was held beyond the competency of the provincial Legislature because it authorized the prejudicial withdrawal of rights and privileges protected by provision 1 of Section 93 of the British North America Act, 1867.
  • Liberty was reserved to the plaintiffs (the appellants) to apply to the Supreme Court of Ontario for relief in accordance with the declaration, should occasion arise; the Lords did not anticipate the need for plaintiffs to exercise that right.
  • Costs: the appeals were allowed with costs to be paid by the respondent Commission both in the Privy Council and below; the respondent Commission was also ordered to pay the costs of the Corporation of the City of Ottawa and of the Quebeck Bank.
  • The opinion states that the decision does not affect the principle of compulsory free primary education in the province established by the School Law of 1850; it noted practical inconvenience that might flow from non-compliance by the trustees, but confined its ruling to the constitutional question of the validity of Section 3.

No broader novel constitutional principle beyond the constitutional construction applied was asserted in the opinion; the decision turned on the construction of Section 3 in light of the protection afforded by Section 93(1).


Source: Opinion of Lord Buckmaster, L.C., as provided. This summary is a faithful condensation of the material contained in the provided opinion and does not add information beyond that text.

Show all summary ...

Lord Buckmaster, L.C.:-

The question raised in these consolidated appeals is whether Sec. 3 of 5 Geo. 5, c. 45 (1915) Ontario is valid and within the competency of the provincial Legislature. The appellants contend that this section prejudicially affects certain rights and privileges with respect to denominational schools reserved under provision 1 of S. 93 of the British North America Act 1867.

The preamble of the Act of 1915 recites that an action was then pending in the Supreme Court of Ontario between R. Mackell and others and the appellants. This action has now been finally decided adversely to the appellants. Their Lordships see no reason to anticipate that this judgment will not be accepted and obeyed. There is a further recital that the appellants have failed to open the schools under their charge at the time appointed by law, and to provide or pay qualified teachers for the said schools, and have threatened at different times to close the said schools and to dismiss the qualified teachers duly engaged for the same. So far as this appeal is concerned the accuracy of these recitals was not questioned by the counsel for the appellants. Sec. 1 of the Act does not come into question in this appeal; S. 2 is a declaration of the duties of the appellants. Sec. 3 is as follows :-

"if, in the opinion of the Minister of Education, the said board fails to comply with any of the provisions of the Act, he shall have power with the approval of the Lieutenant Governor in Council (a) To appoint a Commission of not less than three nor more than seven persons. (6) To vest in and confer upon any Commission so appointed all or any of the powers possessed by the board under statute or otherwise, including the right to deal with and administer the rights, properties, and assets of the board, and all such other powers as he may think proper and expedient to carry out the object and intent of this Act. (c) To suspend or withdraw all or any part of the rights, powers, and privileges of the board, and whenever he may think desirable to restore the whole or any part of the same, and to revest the same in the board, (d) To make such use or disposition of any legislative grant that would be payable to the said board on the warrant of any inspector for the use of the said schools, or any of them, as the Minister may in writing direct."
The acting Minister of Education expressed the opinion that the trustees had failed and were failing to comply with the provisions of the Act, and submitted the appointment of a Commission for the approval of the Lieutenant-Governor in Council. The respondent Commission was duly appointed under an Order in Council on 25th July 1915.

The powers conferred on the Minister of Education in Sub-Ss. (b) and (c) of S. 3 are expressed in very wide terms. At the instance of the Minister, with the approval of the Lieutenant-Governor in Council, all or any part of the rights, powers and privileges of the appellant board may be suspended or withdrawn without limitation in time and only subject to restoration at the discretion of the Minister. The powers withdrawn from the appellant board may be vested and conferred upon an appointed Commission, a nominated body, in the selection of which the rate-paying supporters of the Roman Catholic separate schools have no voice. There is no exception to the universality of the extent to which all the rights, powers, and privileges of the appellant board may be suspended or withdrawn and vested in and conferred upon this nominated body. Is this legislation consistent with provision 1 of Sec. 93 of the British North America Act, 1867? Sec. 93 enacts that

"in and for each province the Legislature may exclusively make laws in relation to education, subject and according to"
certain specified provisions. This section has been recently under the consideration of their Lordships in the case of the appellant board against R. Mackell and others A.I.R. 1916 P.C. 185 1917 A.C. 62 (1917) 86 L.J. P.C. 65. The effect of the section and of Secs. 91 and 92 is to give an exclusive jurisdiction to the Legislature of each province to make laws in reference to education subject to the specified provisions. The Parliament of Canada has no jurisdiction in relation to education, except under the conditions in provision 4, which are not in question in this appeal. The rights or privileges reserved in provision 1 cannot be prejudicially affected without an Act of the Imperial Legislature.

There is no question that the impeached section of the Act of 1915 does authorize the Minister of Education to suspend or withdraw legal rights and privileges with respect to denominational schools. The case of the respondent commission is that the appellant board does not come within the category of "a class of persons", and that no right or privilege with respect to denominational schools, which the appellant board had by law in the province at the Union has been prejudicially affected. It was argued that the protection given by provision 1 related to rights or privileges possessed by all the adherents of the Roman Catholic schools in the Province and that the appellant board only represented the minority of a larger class. The status of the appellant board depends on the provisions contained in the Separate Schools Act, 1863 (26 Vict. c. 5). Sec. 2 of that Act confers the right of electing trustees for the management of a separate school for Roman Catholics, not on all the adherents of Roman Catholic schools in the Province, but on any number of persons, not less than five, being heads of families and freeholders and householders, resident with in any school section of any township or corporate village or town or within any ward of any city or town, and being Roman Catholics. The right of electing managers is thus conferred on the supporters of a separate school or schools for Roman Catholics within one or other of the designated areas. In the present case the appellant board are the elected trustees for the management of Roman Catholic separate schools within the City of Ottawa. They represent the supporters of the Roman Catholic separate schools within the area of the city, an as such elected trustees enjoy the right of management which was conferred under the Separate Schools Act, 1863. Apart therefore from any words of limitation or any implication to be drawn from the context, the appellant board represent a section of the class of persons who are within the protection of provision 1. Their Lordships can find neither limiting words nor anything in the context which would imply that they are excluded from the benefit of the provision. They are not the less within the provision than any other board similarly constituted would have similar rights and privileges. They would be entitled to the protection of the provision, though they were the only board of trustees in the province constituted under the Separate Schools Act, 1863. But if the appellant board represent people who come within the protection of provision 1, it is difficult to appreciate the argument that no legal right or privilege existing in the province at the Union with respect to denominational schools has been prejudicially affected. It is possible that an interference with a legal right or privilege may not in all cases imply that such right or privilege has been prejudicially affected. It is not necessary to consider such a possibility and this question does not arise for decision in the appeal. The case before their Lordships is not that of a mere interference with a right or privilege, but of a provision which enables it to be withdrawn in toto for an indefinite time. Their Lordships have no doubt that the power so given would be exercised with wisdom and moderation but it is the creation of the power and not its exercise that is subject to objection, and the objection would not be removed even though the powers conferred were never exercised at all. To give authority to withdraw a right or privilege under these conditions necessarily operates to the prejudice of the class of persons affected by the withdrawal. Whether or not a different policy might have been preferable either in the opinion of the provincial Legislature or in that of the Courts, is not a relevant consideration. It was argued that no evidence on behalf of the appellant board had been called to prove that the withdrawal of their rights, powers, and privileges operated to their prejudice. In the opinion of their Lordships no such evidence was necessary.

For the purpose of these appeals it is unnecessary to say more. The decision depends on a question of construction. During the argument the counsel for the respondent Commission pressed on their Lordships the difficulty of providing any adequate alternative in order to ensure the proper education of the children of Roman Catholic parents in the City of Ottawa. Their Lordships realize the great importance of this consideration and there is no doubt that considerable temporary inconvenience must be involved if the appellant board, as representatives of the supporters of the Roman Catholic separate schools in Ottawa, fail to open the schools under their charge at the time appointed by law, and to provide and pay qualified teachers. It may be pointed out, however, that the decision in this appeal in no way affects the principle of compulsory free primary education in the province established under the School Law of 1850, 13 and 14 Vict. C. 48, and if the appellant board and their supporters fail to observe the duties incident to the rights and privileges created in their favour the result is that the children of Roman Catholic parents are under obligation to attend the common schools and thus lose the privileges intended to be reserved in their favour under provision 1 of Sec. 93 of the British North America Act, 1867. The history of this question is thus accurately summarized in the judgment of Meredith, C.J.O. (36 Ont. L.R. at P. 491).

"The ground upon which was based the claim of the Roman Catholics to Separate Schools was the injustice of compelling them to contribute to the support of schools to which, owing to the character of the instruction given in them, they could not for conscientious reasons send their children because in their view it was essential to the welfare and proper education of their children that religious instruction according to the tenets of the Roman Catholic Church should be imparted to them as part of their educational training. This injustice, it was claimed, was greatly aggravated when, by the School Law of 1850, a system of compulsory free primary education in schools supported partly by Government grants, but mainly by taxation to which all rate-payers were liable, was established"
.

Their Lordships do not anticipate that the appellants will fail to obey the law now that it has been finally determined. They cannot, however, assent to the proposition that the appellant board are not liable to process if they refuse to perform their statutory obligations or that in this respect they are in a different position from other boards or bodies of trustees entrusted with the performance of public duties which they fail or decline to perform.

From what has been said it appears that in their Lordships' view the Act as framed is ultra vires, and accordingly liberty will be reserved to the plaintiffs, should occasion arise, to apply to the Supreme Court of Ontario for relief in accordance with this declaration but their Lordship do not anticipate that it will be necessary for the plaintiffs to avail themselves of this right.

Their Lordships will humbly advise His Majesty that the appeals be allowed with costs to be paid by the respondent Commission here and below, and the respondent Commission will pay the costs of the Corporation of the City of Ottawa and of the Quebeck Bank.

Appeal allowed.