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A-175-81
Attorney General of Canada (Applicant)
v.
Haig Bozoian (Respondent)
Court of Appeal, Thurlow C.J., Jerome A.C.J. and Kerr D.J.—Ottawa, April 19 and May 7, 1982.
Judicial review — Applications to review — Public Service — Appeal Board decision allowing respondent's appeal against appointment made without competition — Respondent and other candidates unqualified to fill position — Incumbent, seeking lateral transfer, appointed without competition — Respondent's appeal against appointment allowed by Board, on ground of appearance of procedural unfairness not serving best interests of Public Service — Whether Board erred — Failure of Board to consider relative merits of persons whose opportunities for advancement prejudiced by appointment without competition — Dissenting opinion (in part): Board not entitled to substitute its opinion for that of Department — Application granted — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28 — Public Service Employment Act, R.S.C. 1970, c. P-32, ss. 10, 21 — Public Service Employment Regulations, C.R.C. 1978, Vol. XIV, c. 1337, s. 5.
Application to review and set aside the decision of a Public Service Appeal Board which allowed an appeal brought by the respondent under section 21 of the Public Service Employment Act. A competition was held to fill a position; however, all the candidates, including the respondent, failed to meet the mini mum knowledge requirements. Following that result, the incumbent, who had sought a lateral transfer, was appointed without competition pursuant to paragraph 5(c) of the Public Service Employment Regulations. Respondent appealed; the Appeal Board, having found that there had been an appearance of want of procedural fairness, allowed the appeal on the ground that the best interests of the Public Service had not been served. Pursuant to section 10 of the Act, appointments are based on selection according to merit and made by competi tion or other process of personnel selection designed to establish the merits of candidates as the Commission considers is in the best interests of the Public Service. Respondent construes the Board's decision as being to the effect that the merit principle had not been observed in making the selection. The issue is whether the Board erred in making its decision.
Held, the application is granted, the Board's decision is set aside and the matter referred back to the Commission for determination by an appeal board. Respondent's interpretation of the Board's reasons is not sustainable. The Board found that there was an appearance of procedural unfairness due to the fact that the earlier competition had not been extended or that a new competition had not been held. However, it left unan swered a critical question, i.e. whether the selection without
competition took into account the relative merits of the persons whose opportunities for advancement would be prejudiced by the appointment. The answer is "no". The results achieved by the candidates in the examination could not serve as a basis for comparison of their qualifications with those of the person selected as the latter did not enter the competition. Moreover, the case put forward by the Department contains no suggestion that the qualifications of anyone but the incumbent were considered in the selection process or that his qualifications were compared with those of any of the persons whose oppor tunities for advancement would be prejudiced.
Per Kerr D.J. dissenting in part: The Appeal Board exceeded its jurisdiction and erred in law in substituting its opinion for that of the Department and holding that the competition process should have been continued or extended to seek a second series of candidates. The Department, on consideration of the result of the competition and of the incumbent's qualifi cations, rightfully exercised its authority under paragraph 5(c) of the Regulations. Nothing in the record indicates that the Department did not act reasonably and in good faith, or that the appointment was not made "according to merit". The Greaves case is to be distinguished as the appointment in that case was made without any competition having been held.
CASES JUDICIALLY CONSIDERED
CONSIDERED:
Attorney General of Canada v. Appeal Board established by the Public Service Commission, [1982] 1 F.C. 803;
Attorney General of Canada v. Greaves et al., [1982] 1 F.C. 806.
APPLICATION for judicial review. COUNSEL:
E. R. Sojonky for applicant.
M. W. Wright, Q.C. and A. J. Raven for
respondent.
SOLICITORS:
Deputy Attorney General of Canada for applicant.
Soloway, Wright, Houston, Greenberg,
O'Grady, Morin, Ottawa, for respondent.
The following are the reasons for judgment rendered in English by
THURLOW C.J.: This is an application under section 28 of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, to review and set aside a decision of an Appeal Board under section 21 of the Public Service Employment Act, R.S.C. 1970, c. P-32, which allowed an appeal by the respond ent against the appointment of one Vince Dunne to the position of Superintendent of Traffic Opera-
tions, classified at the PM 3 level with the Depart ment of National Revenue (Customs and Excise) at the area port of Pacific Highway, B.C. The selection of Mr. Dunne for the position was made without competition under subparagraph 5(c)(i) of the Public Service Employment Regulations, C.R.C. 1978, Vol. XIV, c. 1337. In allowing the appeal, the Appeal Board concluded that:
The appearance of a want of procedural fairness in the circum stances of this case leads me to conclude that the best interests of the Public Service have not been served by selecting Mr. Dunne for appointment without competition and I allow the appeal against his appointment.
Before setting out the facts it will be convenient to set out the applicable statutory provisions. Regulation 5 prescribes alternative selection proce dures. It provides:
5. Every appointment pursuant to section 10 of the Act shall be made, in accordance with selection standards, by one of the following processes of personnel selection:
(a) an open competition between persons who
(i) respond to public notice, or
(ii) are identified by means of an inventory;
(b) a closed competition between employees who
(i) respond to notice, or
(ii) are identified by means of an inventory; or
(c) the consideration of such material and the conduct of such examinations, tests, interviews and investigations as the Commission considers necessary to establish the merit of a candidate for appointment where the Commission is of the opinion that a competition would not be in the best interests of the Public Service and the appointment is one of the following, namely,
(i) the appointment of an employee to a position for which the maximum rate of pay does not exceed the maximum rate of pay for the position occupied by the employee immediately prior to the appointment,
(ii) the appointment of an employee to a reclassified position that the employee occupied immediately prior to the reclassification of the position,
With respect to the basis of selection for appointment, section 10 of the Act provides:
10. Appointments to or from within the Public Service shall be based on selection according to merit, as determined by the Commission, ând shall be made by the Commission, at the request of the deputy head concerned, by competition or by such other process of personnel selection designed to establish the merit of candidates as the Commission considers is in the best interests of the Public Service.
In Attorney General of Canada v. Greaves et al. [[1982] 1 F.C. 806], this Court held that the concept of "selection according to merit" involves not merely that a successful candidate be qualified for the appointment but that he be the best quali fied of the candidates available for appointment. As between candidates, therefore, what is required is not merely an assessment of the qualifications of the candidates but as well an assessment of their relative merits.
When a candidate has been selected for appoint ment section 21 of the Act comes into play. It provides:
21. Where a person is appointed or is about to be appointed under this Act and the selection of the person for appointment was made from within the Public Service
(a) by closed competition, every unsuccessful candidate, or
(b) without competition, every person whose opportunity for advancement, in the opinion of the Commission, has been prejudicially affected,
may, within such period as the Commission prescribes, appeal against the appointment to a board established by the Commis sion to conduct an inquiry at which the person appealing and the deputy head concerned, or their representatives, are given an opportunity of being heard, and upon being notified of the board's decision on the inquiry the Commission shall,
(c) if the appointment has been made, confirm or revoke the appointment, or
(d) if the appointment has not been made, make or not make
the appointment,
accordingly as the decision of the board requires.
The basic subject matter of the inquiry that is required to be made by a board when an appeal is asserted under this section is whether the selection has been made according to merit as required by section 10. When, therefore, an appellant is being heard pursuant to the section it is open to him to show in any way that he can that the selection has not been made "according to merit" as required by section 10. One conceivable approach would be to show that the selected candidate could not possibly be the best qualified of the candidates or did not meet the requirements for selection whether in terms of personal qualifications or of eligibility for consideration. Another approach might be to chal lenge the way the selection was made so as to show that the selection process itself was illegal or, though legal as a process, was not carried out in a manner calculated to identify the most meritorious candidate. In such an approach it must be remem bered that, under section 10,
(1) the selection is not necessarily to be made by competition but is to be made by competition or other process of personnel selection designed to establish the merit of candidates, and
(2) the decision as to which type of selection process is to be followed is to be made by the Commission on the basis of which process it considers is in the best interests of the Public Service.
In Attorney General of Canada v. Appeal Board established by the Public Service Commission [[1982] 1 F.C. 803], this Court held that an appeal board cannot, on an appeal under section 21 against an appointment made without competi tion pursuant to paragraph 5(c) of the Regula tions, substitute its opinion for that of the Com mission or of its delegate to determine whether a competition would not be in the best interests of the Public Service. That, however, leaves untouched the requirement that the selection when made, and by whatever process of selection it is made, be made according to merit. (Attorney Gen eral of Canada v. Greaves et al., supra.)
I turn now to the facts. They are recited as follows in the judgment of the Appeal Board:
The facts of the case appear not to be in dispute. In Septem- ber 1980, the Department initiated a competition to fill the position of Superintendent Traffic Operations. Prior to the competition, the appellant had requested a "lateral transfer" from his present position which was also classified at the PM 3 level to a Superintendent position. However, it was anticipated that a number of employees would be interested in the position of Superintendent of Traffic Operations and O. McCrae, the manager responsible for the position, expressed the view that it would be better to conduct a competition in order to identify someone for appointment. Consequently, no consideration was given to the requests for "lateral transfers" that had been submitted. The competition was conducted and the qualifica tions of five candidates, including the appellant, were assessed on the basis of their responses to a series of preset questions at an interview. None of the five candidates were considered to have demonstrated the minimum knowledge required to effi ciently perform the duties of the position and all were eliminat ed from the competition. All candidates were advised that the competition had not been fruitful in terms of identifying some one for appointment by letter dated December 10, 1980.
On December 15, 1980, V. Dunne who occupied a position of Training and Development Advisor, classified at the PE 2 level, requested a "lateral transfer" to the position of Superintendent Traffic Operations. Mr. McCrae knew Mr. Dunne because he had supervised him from 1974 to 1976 when Mr. Dunne occupied a position similar to the position to be filled. Mr.
McCrae was also aware that since 1976 Mr. Dunne had been a Training and Development Coordinator and had been active in developing technical training programs for Customs Inspectors and Superintendents. On the basis of his personal knowledge of Mr. Dunne's qualifications, Mr. McCrae concluded that he could carry out the duties of the position to be filled and selected him for appointment. Mr. McCrae prepared the fol lowing narrative comments on Mr. Dunne:
Knowledge—Mr. V. J. Dunne previously encumbered a posi tion titled Superintendent Outside Services, at the PM 3 level at Pacific Highway during the period 1973-1976.
Mr. Dunne was under my general supervision from Septem- ber 1974 through December 1976. During this period Mr. Dunne demonstrated he possessed a very good knowledge of the Customs Act, Excise Act, Excise Tax Act, Customs Tariff and related regulations, directives and procedures as well as those of other government agencies administered on their behalf by Customs and Excise.
Abilities—Mr. Dunne has satisfactorily demonstrated the ability to identify and resolve problems and implement remedial action, apply the provisions of the collective agree ments, communicate effectively, direct and train staff.
Personal Suitability—Mr. Dunne enjoys the ability to estab lish and maintain good interpersonal working relations with representatives of Customs House, brokerage firms, transpor tation companies and members of other enforcement agencies.
He is tactful and exercises discretion and good judgement. The position Superintendent Traffic Operations to which he is being appointed is almost identical to the former position of Superintendent Outside Services.
The Department posted a "notice of right to appeal" the appointment and Mr. Bozoian lodged an appeal.
This recital of the facts was followed by a recital of the case raised on behalf of the respondent.
The appellant, through his representative, argued that Mr. McCrae could not have fully assessed Mr. Dunne's qualifica tions solely on the basis of his personal knowledge of Mr. Dunne's past employment history. Firstly, Mr. McCrae had not supervised Mr. Dunne for some four years and, therefore, his knowledge of Mr. Dunne's skills was outdated. Secondly, the position to be filled was a new position and there was no real grounds on which Mr. McCrae could reasonably conclude whether Mr. Dunne would be able to effectively perform the duties.
As to these contentions, the Board said:
Secondly, was there sufficient information on the candidate being considered for appointment from which it could be concluded whether the candidate possessed the qualifications to efficiently perform the duties of the position to be filled? These questions arise with respect to the obligation that the regulation appears to impose. In this case, the appellant has raised only the question dealing with Mr. Dunne's qualifications. I am of the view that a reasonable assessment can be made of an
individual's qualifications on the basis of past observation and the appellant has provided no convincing argument to lead me to conclude that Mr. McCrae could not have made some intelligent assessment of Mr. Dunne's qualifications on the basis of his knowledge of Mr. Dunne's work history.
It will be observed that what was raised on behalf of the respondent was not whether he, Mr. Bozoian, was qualified for the appointment. Nor was it whether he was better qualified for it than Mr. Dunne. What was raised was simply whether Mr. Dunne was qualified for the appointment and on this the Board upheld the assessment made by Mr. McCrae. As I see it, there is nothing wrong in law with that particular finding of the Appeal Board and I do not recall any challenge to it having been made on the hearing of the present application.
The Appeal Board, however, went on to consider whether or not it was in the best interests of the Public Service to select Mr. Dunne for appoint ment without competition and, having concluded that there had been an appearance of want of procedural fairness, went on to allow the appeal, as already indicated, on the ground that the best interests of the Public Service had not been served by selecting Mr. Dunne for appointment without competition.
On the hearing in this Court counsel for the respondent did not seek to support the authority of the Appeal Board to decide what process of selec tion is in the best interests of the Public Service. His submission, as I understood it, was that the substance of what the Board had decided was that the merit principle had not been observed in making the selection.
In the way the reasons of the Appeal Board are expressed there is something to be said for the submission but after reading and re-reading the reasons I am unable to conclude that that interpre tation should be put on what the Board said.
What the Board, as I read the reasons, purport ed to decide was that the earlier competition should have been extended or a new competition should have been held and that because it was not held there was an appearance of procedural unfair ness which was not in the best interests of the Public Service. However, having made that finding and having also found that Mr. Dunne was quali-
fied for the appointment, it appears to me that what the Board has done is to leave unanswered and undecided what I conceive to be the critical question for the inquiry, that is to say, whether in the circumstances disclosed the process of selection of Mr. Dunne for appointment without competi tion was carried out in a manner that took into account the relative merits of the persons whose opportunity for advancement would be prejudiced by the appointment.
It must be remembered that Mr. Dunne had not been a candidate in the competition that had been held earlier. As he had not been asked the ques tions that were required to be answered by those who were candidates, no one knows what score he might have made. There is thus nothing in the record to show that he would have fared any better than the candidates fared on that examination. The results achieved by the candidates in it could not, therefore, in my opinion, serve as a basis for comparison of their qualifications with those of Mr. Dunne in a selection for appointment subse quently made without competition. Moreover, the recital by the Board of the case put forward by the Department at the inquiry, while setting out facts from which it might be concluded that Mr. Dunne had the necessary qualifications, contains no suggestion that the qualifications of anyone but Mr. Dunne were considered in the selection pro cess or that his qualifications were compared with those of any of the persons whose opportunities for advancement would be prejudiced by his being selected for appointment.
I would set aside the decision and refer the matter back to the Commission for determination by an appeal board after considering the question whether the selection of Mr. Dunne for appoint ment without competition was made according to merit as required by section 10 of the Public Service Employment Act.
JEROME A.C.J.: I concur.
* * *
The following are the reasons for judgment rendered in English by
KERR D.J. (dissenting in part): This is an application pursuant to section 28 of the Federal
Court Act to review and set aside a decision of the Public Service Appeal Board dated March 10, 1981. The decision, signed by the Board's Chair man, allowed an appeal brought by the respondent herein, Haig Bozoian, against the selection of Mr. V. J. Dunne to fill a vacant position of Superin tendent Traffic Operations with the Department of National Revenue (Customs and Excise) at the area port of Pacific Highway, British Columbia.
In September 1980 the Department initiated a competition to fill the position. The qualifications of five candidates, including Mr. Bozoian, were assessed by a Rating Board on the basis of their responses to a series of questions at an interview held by the Board on December 2, 1980. The Board decided that none of the candidates had demonstrated the essential minimum "Knowledge" requirement to efficiently perform the duties of the position. That essential knowledge requirement is set forth in the statement of qualifications for the position, as follows:
ESSENTIAL REQUIREMENTS
Knowledge
—Knowledge of the Customs Act, Customs Tariff and parts of the Excise Tax Act, and related regulations, directives and procedures governing the movement of people, goods and vehicles entering Canada;
—Knowledge of the relevant parts of Acts and regulations of other Departments, administered by Customs on their behalf;
—Knowledge of departmental practices and procedures in respect to administrative and personnel matters.
One other person had filed an application in the competition, but too late, and, therefore, he was not interviewed. Mr. Dunne was not a candidate in the competition. The candidates were advised by letter dated December 10, 1980 that the competi tion had not been fruitful in terms of identifying someone for appointment to the vacant position. I think that the decisions of the Rating Board should be treated as valid.
The next development in the process of filling the position is set forth in the following portion of the Appeal Board's decision:
On December 15, 1980, V. Dunne who occupied a position of Training and Development Advisor, classified at the PE 2 level, requested a "lateral transfer" to the position of Superintendent
Traffic Operations. Mr. McCrae knew Mr. Dunne because he had supervised him from 1974 to 1976 when Mr. Dunne occupied a position similar to the position to be filled. Mr. McCrae was also aware that since 1976 Mr. Dunne had been a Training and Development Coordinator and had been active in developing technical training programs for Customs Inspectors and Superintendents. On the basis of his personal knowledge of Mr. Dunne's qualifications, Mr. McCrae concluded that he could carry out the duties of the position to be filled and selected him for appointment. Mr. McCrae prepared the fol lowing narrative comments on Mr. Dunne:
Knowledge—Mr. V. J. Dunne previously encumbered a posi tion titled Superintendent Outside Services, at the PM 3 level at Pacific Highway during the period 1973-1976.
Mr. Dunne was under my general supervision from Septem- ber 1974 through December 1976. During this period Mr. Dunne demonstrated he possessed a very good knowledge of the Customs Act, Excise Act, Excise Tax Act, Customs Tariff and related regulations, directives and procedures as well as those of other government agencies administered on their behalf by Customs and Excise.
Abilities—Mr. Dunne has satisfactorily demonstrated the ability to identify and resolve problems and implement remedial action, apply the provisions of the collective agree ments, communicate effectively, direct and train staff.
Personal Suitability—Mr. Dunne enjoys the ability to estab lish and maintain good interpersonal working relations with representatives of Customs House, brokerage firms, transpor tation companies and members of other enforcement agencies.
He is tactful and exercises discretion and good judgement. The position Superintendent Traffic Operations to which he is being appointed is almost identical to the former position of Superintendent Outside Services.
The Department posted a "notice of right to appeal" the appointment and Mr. Bozoian lodged an appeal.
It appears from the Appeal Board's decision that the Board had queried why Mr. Dunne did not attend the Board's inquiry or enter the compe tition, and also that it had given consideration to the question "whether or not it was in the best interests of the Public Service to select Mr. Dunne for appointment without competition." The last two paragraphs of the decision read as follows:
I pointed out my concerns to the Department at the inquiry and invited the representative to comment on the suggestion that it appeared unfair for Mr. Dunne to be considered for appointment without competition. It was, in my view, difficult to understand why Mr. Dunne did not compete for the position if he was interested in it when the competition was advertised. The Department's representative explained that he did not know why Mr. Dunne did not participate in the competition nor did he know why Mr. Dunne requested a "lateral transfer" only after the results of the competition had been released. He
suggested that it would only be conjecture to search for Mr. Dunne's motives. He could only clearly explain the actions taken by the Department and on the basis of the information before it he considered that the Department had acted in a reasonable manner.
I agree that the best person to explain Mr. Dunne's motives would be Mr. Dunne himself. Unfortunately, he chose not to attend the appeal inquiry even though he was invited to do so. Consequently, Mr. Dunne himself has provided no information on why he did not participate in the competition even though he was eligible to do so. As a result, the perception of a want of procedural fairness in making the selection for appointment remains with me and I am left with the impression that Mr. Dunne hovered in the wings until he had nobody to compete with for the position. As I noted in the case of Kelly (identified earlier), in my view it is intended that selections for appoint ment from within the Public Service normally be made by competition. A competition was initiated in this case and I am of the opinion that the competition should have been extended before attempting to fill the vacant position by other means. If, after the results of the competition were released, other poten tial candidates identified themselves, then the competition could easily have been continued so that the relative merit of the second series of candidates could be easily compared with that of the first group. Alternatively, the area of competition could have been expanded. In other words, a thorough pursuit for a successful candidate should be made by competition before considering the merit of only one person for appointment without competition. The appearance of a want of procedural fairness in the circumstances of this case leads me to conclude that the best interests of the Public Service have not been served by selecting Mr. Dunne for appointment without compe tition and I allow the appeal against his appointment.
I see no useful purpose in speculating as to why Mr. Dunne did not enter the competition or attend the Board's inquiry. The competition ran its course without him; and a representative of the Depart ment that appointed him to the vacant position attended before the Board to speak in respect of the Department's action, the procedure followed, and the selection and appointment of Mr. Dunne.
In several recent cases this Court has considered the "merit principle" and requirements and proce dures for appointments to or from within the Public Service, particularly sections 10 and 21 of the Public Service Employment Act and section 5 of the Public Service Employment Regulations. I will refer to two of the cases and repeat here verbatim certain portions of the respective reasons for judgment.
In Attorney General of Canada v. Appeal Board established by the Public Service Commission [supra], Heald J. said [at pages 803-804]:
We are all of the opinion that the respondent Board, having found (Case, page 124):
... that the Department had sufficient evidence upon which to conclude that Mrs. McArthur had the qualifications required to perform the duties of the position under appeal
exceeded its jurisdiction in proceeding to substitute its opinion for the opinion of the Department to which the Public Service Commission had delegated the authority to determine whether a competition would or would not be in the best interests of the Public Service pursuant to subparagraph 5(c)(i) of the Public Service Employment Regulations, C.R.C. 1978, Vol XIV, c. 1337, as amended.
The function of an Appeal Board appointed pursuant to section 21 of the Public Service Employment Act, R.S.C. 1970, c. P-32, is to determine, after inquiry, whether the selection made in the instant case was a "selection according to merit" pursuant to section 10 of that Act. The Appeal Board has a right and duty to satisfy itself that the opinion required by subsection 5(c)(i) of the Regulations, supra, was in fact formed but it cannot review the reasonableness of the opinion so long as there was some basis for it. The opinion formed would have to be so unreasonable that no reasonable person could form that opinion. The Appeal Board is not entitled to substitute its opinion for that of the Department exercising the delegated authority to form that opinion. The question whether there has been the required opinion formed is relevant to the application of the merit principle, but as to the reasonableness of such opinion, an Appeal Board should be bound by the same limits as a Court exercising judicial review or sitting on a statutory appeal. In our view, on the facts of this case, there was ample evidence upon which the Department could reach the conclu sion which it did, namely, that it was necessary to transfer Mrs. McArthur for humanitarian or compassionate reasons. On this basis, the Appeal Board was not entitled to substitute its opinion for that of the Department and thus, exceeded its jurisdiction.
In Attorney General of Canada v. Greaves et al. [supra] in which this Court dismissed an applica tion to set aside a decision of the Appeal Board that had allowed appeals against the appointment of one Brian Dougall under paragraph 5(c) of the Public Service Employment Regulations, Pratte J. said [at pages 810-811]:
A selection which has been made in accordance with the procedure laid down in the Act and the Regulations, be it by competition or otherwise, may nevertheless be successfully attacked under section 21 if the manner in which the selection was made was such that it violated the merit principle. For instance, a selection made by competition following all the statutory requirements may be tainted by the fact the qualifica tions of the candidates have been wrongfully assessed. This is true when the selection is made by competition; it is also true if the selection is made without a competition. The requirements of the merit principle are, in my view, always the same. They
do not vary with the method of selection chosen. That principle requires that the selection be made "according to merit", which means, "that the best persons possible will be found for the various positions in the Public Service ...". In the present case, the Appeal Board, as I understand its decision, was not satisfied that the appointment had been made "according to merit" because the qualifications of the selected candidate had never been in any way compared with those of other persons who, like the respondents, might have wished to apply for the position. This was, in my view, a valid reason for allowing the appeal.
And in that case Le Dain J. agreed that the section 28 application should be dismissed, and he said [at pages 811-812]:
Sections 10 and 21 of the Public Service Employment Act indicate that an appointment may be made in the Public Service without competition. To that extent paragraph 5(c) of the Public Service Employment Regulations, which provides for appointment without competition, finds support in the legislation. But the alternative process of personnel selection chosen by the Commission must be one which, in the words of section 10 of the Act, is "designed to establish the merit of candidates." The merit established by competition is obviously relative merit. I agree that we would not be justified in concluding that the word "merit" in the part of section 10 which reads, "such other process of personnel selection designed to establish the merit of candidates as the Commission considers is in the best interests of the Public Service," is intended to have the different and more limited meaning of simply being qualified for a position. I believe the merit princi ple was intended to achieve more than merely the appointment of qualified persons in the Public Service. Its purpose is to find the best qualified persons from among those who are available. In the case of a competition the persons who are available are identified as candidates for the position. The Commission, or those exercising its delegated authority, know for certain the persons whose qualifications for the position must be compared in the light of the merit principle in order to comply with the requirement of section 10 of the Act. In the case of an appointment without competition there is not an identification of other candidates for the position. This is clear from a comparison of paragraphs (a) and (b) with paragraph (c) of section 5 of the Regulations. flow, then, is the Commission, or those exercising its delegated authority, to know who the candidate for appointment is to be compared with in order to satisfy the requirement of section 10? In my opinion, it is an implication of section 21 of the Act, which gives a right of appeal, in the case of an appointment without competition, to "every person whose opportunity for advancement, in the opin ion of the Commission, has been prejudicially affected", that the candidate's qualifications must be compared with those of the persons whose opportunities for advancement would be prejudicially affected by his or her appointment. Such persons are usually identified after a selection is made, as happened in the present case after the first selection which led to the first decision of the Appeal Board, but they may, as a practical matter, be identified before a selection is made, and should there be any oversight in this respect it may be subsequently corrected. I am mindful that the conclusion reached in this case may severely limit the flexibility provided by the power of
transfer in the Public Service, to the extent that a particular transfer constitutes an appointment within the meaning of the Act, but if more is required in this regard it should be clearly provided by the legislation.
It is clear that when Mr. Dunne made his application to be transferred to the vacant position the process of selection by advertised competition had been tried, extending in all over a period of several months, and that the competition had not disclosed any person qualified for the position. Thereupon, on consideration of the fact of the competition and its result, and Mr. Dunne's application and his qualifications, the Department exercised its authority under paragraph 5(c) of the Public Service Employment Regulations and selected him to fill the position. The situation in the so-called "Greaves case", above mentioned, was different for in that case, as I recall it, the appointment of Brian Dougall was made without any competition having been called or held and the Department was aware before it made the appoint ment that certain employees were opposed to the appointment on the ground that their opportunity for advancement would thereby be prejudicially affected; and the Department, notwithstanding that awareness, did not compare his qualifications with whatever qualifications those other employees had for the position.
In my view, in the circumstances of this case there was ample evidence upon which the Depart ment could reach its conclusion to act under sub- paragraph 5(c)(i) of the Public Service Employ ment Regulations and appoint Mr. Dunne to the vacant position, and the Appeal Board was not entitled to substitute therefor its opinion that the competition process should be continued or extend ed to seek a second series of candidates. In doing so it exceeded its jurisdiction and erred in law.
In the record before this Court on this applica tion I do not see anything that should give me cause to doubt that in proceeding as it did and appointing Mr. Dunne the Department acted rea sonably and in good faith and that the appoint ment was made "according to merit".
Therefore, my conclusion is that this section 28 application should be granted and that the decision of the Appeal Board should be set aside.
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