Judgments

Decision Information

Decision Content

A-24-85
Okanagan Helicopters Ltd. (Applicant) v.
Canadian Helicopter Pilots' Association (Respondent)
INDEXED AS: OKANAGAN HELICOPTERS LTD. V. CANADIAN HELICOPTER PILOTS' ASSN.
Court of Appeal, Heald, Hugessen and Stone JJ.—Vancouver, December 5 and 6; Ottawa, December 19, 1985.
Judicial review — Applications to review — Labour rela tions — Dues check off — "Interim" ruling by Canada Labour Relations Board re applicability of new legislation to existing collective agreement "decision" within Code s. 120.1(2) and Act s. 28, and therefore subject to judicial review — As interest of dissenting bargaining unit members herein with respect to dues check off different from interest of union, Board's failure to give said members notice of proceeding where "interim" ruling made contrary to rules of natural justice — Dissenting members having sufficient interest to raise issues in s. 28 application — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28 — Canada Labour Code, R.S.C. 1970, c. L-1, ss. 120.1 (as enacted by S.C. 1977-78, c. 27, s. 42), 162 (as am. by S.C. 1984, c. 39, s. 31), 184 (as enacted by S.C. 1972, c. 18, s. 1) — Federal Court Rules, C.R.C., c. 663, RR. 1401(3), 1403(1),(2), 1404, 1405, 1406 (as am. by SOR/79-57, s. 25), 1409.
Labour relations — Dues check off — Representative role of union as certified agent for bargaining unit members — Rights of individual members with respect to Labour Relations Board "interim" ruling and s. 28 application where members' interest different from union's — Dissenting members had right to notice of proceeding wherein "interim" ruling made — Canada Labour Code, R.S.C. 1970, c. L-1, ss. 120.1 (as enacted by S.C. 1977-78, c. 27, s. 42), 162 (as am. by S.C. 1984, c. 39, s. 31), 184 (as enacted by S.C. 1972, c. 18, s. 1) — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28.
A collective agreement included a "modified Rand" check off clause whereby employees who did not wish to have their union dues deducted at source could opt out of the check off. Before the expiry of that collective agreement, an amendment to the Canada Labour Code made the check off compulsory if the union requested it. When the employer refused the union's request that a Rand formula be included in the existing collec tive agreement, the union filed a complaint of unfair labour practice before the Canada Labour Relations Board. The Board summoned the parties to a hearing to discuss the applic ability of the new legislation to existing collective agreements.
The Board refused to give notice of that hearing to the employees at large and, in particular, to those who had opted out of compulsory check off.
The Board first ruled that the new legislation was applicable to existing contracts. When the parties failed to settle their differences in the light of this ruling, it then ruled that the employer's refusal was an unfair labour practice and ordered it to retroactively include the compulsory dues check off in the then expired collective agreement.
This is a section 28 application against both decisions of the Board, with two dissenting employees intervening.
The first issue is whether the Board's first ruling was a "decision" within the meaning of section 28 of the Federal Court Act or only a preliminary or incidental determination or expression of opinion which have been held not to be "decisions".
The second issue is whether the question of the absence of notice to the dissenting employees is properly before the Court. In this regard, it is argued, firstly, that the employer has no interest in the absence of notice and therefore cannot be heard to argue that point and, secondly, that the dissenting employees have standing only as intervenors and cannot raise a question which is peculiar to them only.
Held, the application should be allowed.
Section 120.1 of the Code specifically mandates the Board to make interim decisions which are expressly qualified as "final". The interim ruling on the applicability of the new legislation to the existing collective agreement is therefore a decision within the meaning of section 28 of the Federal Court Act and the Court has jurisdiction to review it.
The employer cannot invoke the absence of notice to attack the Board's decisions since the employer was the very person whose duty it was to give that notice. A denial of natural justice, caused by a failure to notify an interested person of proceedings by which his rights may be affected, results in the ensuing decision being voidable at the instance of that person only.
The dissenting employees have the necessary standing to raise a question which is peculiar to them only. The judicial review provisions of the Act and Rules permit any interested person, subject to minimal procedural requirements, to partici pate in the hearing of a section 28 application and to raise whatever questions he deems proper.
The underlying issue in this case is the representative role of a trade union as the certified bargaining agent for the members of the bargaining unit. As a general rule the union acts for or in conjunction with the employee with respect to collective agree ments or the enforcement of rights arising thereunder. The Courts have held, however, that where an employee has a patrimonial interest which is actually opposed to that of the
union or of other members whose interests the union has chosen to espouse, such an employee has standing and is a necessary party to proceedings before the appropriate tribunal. An employee who has exercised the option to revoke his dues check off has a vested right not to have his dues checked off and has a legitimate interest in urging that the legislation revoking that right is invalid or does not have the effect contended for by the union, especially when the retroactive application of the Rand formula to wages already paid is at stake. In those circum stances, it is beyond dispute that the interests of the union and those of the dissenting employees were directly opposed to one another.
The Board therefore ought to have given notice to the employees before embarking on its enquiry.
CASES JUDICIALLY CONSIDERED
APPLIED:
Anheuser-Busch, Inc. v. Carling O'Keefe Breweries of Canada Limited, [1983] 2 F.C. 71 (C.A.); Hoogendoorn v. Greening Metal Products and Screening Equipment Company et al., [1968] S.C.R. 30; Re Bradley and Ottawa Professional Fire Fighters Assn., [1967] 2 O.R. 311 (C.A.); Appleton v. Eastern Provincial Airways Ltd., [1984] 1 F.C. 367 (C.A.).
DISTINGUISHED:
Attorney General of Canada v. Cylien, [1973] F.C. 1166 (C.A.); B.C. Packers Ltd. v. Canada Labour Relations Board, [1973] F.C. 1194 (C.A.); Anti-dumping Act (In re) and in re Danmor Shoe Co. Ltd., [1974] 1 F.C. 22 (C.A.); Paul L'Anglais Inc. v. Canada Labour Relations Board, [1979] 2 F.C. 444 (C.A.); Syndicat des employés de production du Québec et de l'Acadie v. Canada Labour Relations Board et al., [1984] 2 S.C.R. 412; (1985), 55 N.R. 321.
REFERRED To:
General Motors of Canada Ltd. v. Brunet, [1977] 2 S.C.R. 537.
COUNSEL:
Katherine J. Heller for applicant.
James E. Dorsey for respondent Canadian
Helicopter Pilots' Association.
Diane Pothier for respondent Canada Labour
Relations Board.
William C. Kaplan for intervenors Mark Gil-
bert and Jerry Cutler.
SOLICITORS:
Russell & DuMoulin, Vancouver, for appli cant.
Braidwood, Nuttall, MacKenzie, Brewer & Greyell, Vancouver, for respondent Canadian Helicopter Pilots' Association.
Canada Labour Relations Board, Ottawa, on its own behalf.
Jordan & Gall, Vancouver, for intervenors Mark Gilbert and Jerry Cutler.
The following are the reasons for judgment rendered in English by
HUGESSEN J.: This is a section 28 application against an "interim" decision of the Canada Labour Relations Board given December 21, 1984. It was heard at the same time as the section 28 application in Court file No. A-573-85, directed against a further decision rendered June 18, 1985, by which the Board purported finally to dispose of the matter before it. It is convenient to set out the background to both decisions together.
Canadian Helicopter Pilots' Association (the union) is the certified bargaining agent for a group of employees of Okanagan Helicopters Ltd. (the employer). A collective agreement was entered into between them for the period February 1, 1983—January 31, 1985. Article 2.03' of that agreement provided a "modified Rand" check off clause. The most important feature of that clause was that it preserved, subject to strict time con straints, the right of employees who did not wish to have their union dues deducted at the source to opt out of the check off. In fact, the record indicates that considerable numbers of employees exercised this option and that, in October 1984, only eight out of eighteen members of the bargaining unit (44 per cent) were subject to check off. In June
' 2.03 During the term of this agreement, the Company will deduct from the employees covered by this agree ment the Association membership dues and initiation fees in accordance with the terms and procedures below:
a) current employees:
(i) employees currently authorizing dues deduction may revoke their authorization in writing 30-60 days following the ratification of the agreement by the parties. Failure to revoke such authoriza tion will result in the dues deduction becoming non-revocable,
(Continued on next page)
1984, Parliament amended section 162 of the Canada Labour Code [R.S.C. 1970, c. L-1 (as am. by S.C. 1984, c. 39, s. 31)]. The new text, which was proclaimed in force July 18, 1984, effected an important change in the law:
Compulsory Check Off
162. (1) Where a trade union that is the bargaining agent for employees in a bargaining unit so requests, there shall be included in the collective agreement between the trade union and the employer of the employees a provision requiring the employer to deduct from the wages of each employee in the unit affected by the collective agreement, whether or not the employee is a member of the union, the amount of the regular union dues and to remit the amount to the trade union forthwith.
As can be seen, this new text makes the "Rand formula" obligatory. All that is required is for a certified bargaining agent to request it and the formula
... shall be included in the collective agreement between the trade union and the employer ....
Almost immediately after the coming into force of the new legislation, the union requested the inclusion of a Rand formula in the existing collec tive agreement. On the employer's refusal, the union filed a complaint of unfair labour practice under section 184 [as enacted by S.C. 1972, c. 18, s. 1]. The Board summoned the parties to a hear ing in December 1984, at which the single issue discussed was the applicability of the new legisla tion to existing collective agreements. Although requested to do so by the employer, the Board
(Continued from previous page)
(ii) employees not authorizing dues deduction will sign a form authorizing dues deduction within 28 days of the ratification of the agreement by the parties. These employees will have a period of 30-60 days from the time of signing the authorization to revoke such authorization in writing. Failure to revoke such authorization will result in the dues deduction becoming effec tive following the 60 day period and non-revo cable,
b) individuals recalled from layoff:
(i) individuals who had previously authorized dues deduction may revoke their authorization in writing 30-60 days following their return to work. Failure to revoke such authorization will result in the dues deduction becoming non-revo cable,
refused to give notice of that hearing to the employees at large and, in particular, to those employees who had previously opted out of com pulsory check off.
By its decision of December 21, 1984, the Board, by a majority, ruled that the new legisla tion was indeed applicable to existing contracts. It referred the matter back to the parties with an exhortation to them to settle their differences in the light of this ruling. It also arranged for copies of its decision to be given to all the employees in the bargaining unit.
The Board's hopes of settlement proved vain and, in due course, hearings on the original com plaint were resumed April 30 and May 1, 1985. In the meantime, two of the dissenting employees, Messrs. Gilbert and Cutler, who it will be recalled had been notified of the December 21, 1984 deci sion but not of the proceedings leading up to it, intervened and were granted standing in the pro- ceedings,--before the Board. By its decision of June 18, 1985, the Board found that the employer's refusal to give effect to the new section 162 con stituted an unfair labour practice within the mean ing of section 184. As a remedy, it ordered the employer to retroactively include compulsory dues check off in the by then expired collective agree ment with effect from the end of July 1984.
(Continued from previous page)
(ii) individuals who had not previously authorized dues deduction will sign a form authorizing dues deduction at the time of re-employment. These individuals will have a period of 30-60 days from the time of signing the authorization to revoke in writing such authorization. Failure to revoke such authorization will result in the dues deduction becoming effective following the 60 day period and non-revocable.
c) newly hired employees within the certifiction (sic) or employees transferred into the certification will sign a form authorizing dues deduction at the time of hire or transfer. These employees will have a period of 30-60 days from the time of signing the authoriza tion to revoke such authorization in writing. Failure to revoke such authorization will result in the dues deduction becoming effective following the 60 day period and non-revocable.
As indicated at the outset, the employer has launched section 28 proceedings against both deci sions of the Board and these proceedings were heard at Vancouver December 5 and 6, 1985. On December 3, 1985, the employees Gilbert and Cutler, who, as already stated, had intervened in the second set of proceedings before the Board, filed a notice of motion in this Court pursuant to Rule 1405(1) [Federal Court Rules, C.R.C., c. 663] seeking leave to be heard on the argument on the first application (Court file No. A-24-85). Leave was granted at the opening of the hearing on December 5 and counsel for Messrs. Gilbert and Cutler filed a memorandum of fact and law and were heard.
At the very threshold of these proceedings is the question as to whether the Board's ruling (to use a neutral term) of December 21, 1984, was a "deci- sion" within the meaning of section 28 of the Federal Court Act [R.S.C. 1970 (2nd Supp.), c. 10]. As the Board itself said in that ruling, it had "only clarified the law". No order was made and the original complaint under section 184 was not disposed of in any way.
In appearance, the ruling of December 21, 1984 has therefore all the characteristics of the sort of preliminary or incidental determination or expres sion of opinion which have been held by this Court not to be "decisions" within the meaning of section 28. 2 As stated by this Court in Anheuser-Busch, Inc. v. Carling O'Keefe Breweries of Canada Lim ited, [1983] 2 F.C. 71 (C.A.) [at page 75], section 28 gives us jurisdiction to review
... only final orders or decisions—that is—final in the sense that the decision or order in issue is the one that the tribunal has been mandated to make and is a decision from which legal rights or obligations flow.
The position of the Board is however, in this respect, different from that of many, if not most,
2 See, for example: Attorney General of Canada v. Cylien, [1973] F.C. 1166 (C.A.); B.C. Packers Ltd. v. Canada Labour Relations Board, [1973] F.C. 1194 (C.A.); Anti-dumping Act (In re) and in re Danmor Shoe Co. Ltd., [1974] 1 F.C. 22 (C.A.).
other administrative tribunals. The Board is, by its constituent statute, specifically mandated to make interim decisions in the course of deciding any matter before it, which decisions may deal with only one or some of the issues before it but are nevertheless final. Such is the effect of section 120.1 of the Code [as enacted by S.C. 1977-78, c. 27, s. 42]. 3
In the present case, the Board had before it a complaint of unfair labour practice under section 184. Clearly one of the issues arising from that complaint was the application of the new text of section 162 to existing collective agreements. While the ruling of December 21, 1984, does not contain or incorporate a formal order or declara tion, it does resolve that issue in unmistakable terms:
Parliament has, as of July 18, 1984, created a minimum standard for the deduction and remittance of union dues for employees who are affected by a collective agreement in the federal jurisdiction, to which the Code applies. The only requirements for that standard to apply are that there is a collective agreement in force and the trade union which is the bargaining agent so requests. (Decision, Case, p. 211).
Furthermore this issue was not one on which the Board was simply, as a preliminary matter, obliged to take a position without having any power or jurisdiction to decide it. 4 Rather, it was a matter which fell squarely within the jurisdiction and powers of the Board. The Board's decision on such a matter is, in the words of subsection 120.1(2), "final". It was treated as such by all concerned during the second set of hearings, when no submis sions were sought or made regarding the applica tion of section 162 to existing agreements.
3 120.1 (1) Where, in order to dispose finally of an applica tion or complaint it is necessary for the Board to determine two or more issues arising therefrom, the Board may, if it is satisfied that it can do so without prejudice to the rights of any party to the proceeding, issue a decision resolving only one or some of those issues and reserve its jurisdiction to dispose of the remaining issues.
(2) A decision referred to in subsection (1) is, except as stipulated by the Board, final.
(3) In this section, "decision" includes an order, a determina tion and a declaration.
4 See, for example, Paul L'Anglais Inc. v. Canada Labour Relations Board, [1979] 2 F.C. 444 (C.A.).
In the circumstances, I am satisfied that the ruling of December 21, 1984 is a decision within the meaning of section 28 of the Federal Court Act, and that we have jurisdiction to review it.
The only serious questions which arise on such review are those resulting from the failure of the Board to give notice of the proceedings leading to its ruling of December 21, 1984 to those members of the bargaining unit who had elected, under article 2.03 of the collective agreement, to opt out of dues check off.
It was suggested in argument that the question of the absence of notice to the dissenting employees was not properly before us at all and therefore should not be considered. The argument proceeds in two steps:
1. The employer, who initiated the section 28 application, has no interest in and therefore cannot be heard to argue the absence of notice.
2. The dissenting employees have standing only as intervenors and therefore cannot raise a ques tion which is peculiar to them only.
I am prepared to concede the first step. The proposition that a denial of natural justice, caused by a failure to notify an interested person of proceedings by which his rights may be affected, results in the ensuing decision being voidable at the instance only of that person seems to me to be sound. Indeed to hold the contrary could lead to the absurdity of a decision being set aside on those grounds at the instance of the very person whose duty it was to give the notice in question.
The second branch of the argument appears to me, however, unsupportable. In my opinion, the whole thrust of section 28 of the Federal Court Act when read with Division D of Part V of the Rules is that multiple applications are not encouraged and that any interested person is at liberty, subject to minimal procedural require ments, to participate in the hearing of a section 28 application and to have standing to raise whatever questions seem to him to be proper. I would refer, in particular, to Rules 1401(3), 1403(1) and (2), 1404, 1405 and 1406 [as am. by SOR/79-57, s. 25]
and the definition of "interested person" in Rule 1409. That being so, it does not surprise me that counsel were not able to find any reported case to support the proposition.
Accordingly, I conclude on this aspect of the matter that we are properly seized of the question of the effect of the Board's failure to give notice to the employees of the proceedings leading up to the December 21, 1984, decision.
The issue is at bottom that of the representative role of a trade union as the certified bargaining agent for the members of the bargaining unit. As a general rule, the union acts for and binds the employees, who individually have no standing in collective bargaining relations with their employer. Without the support and participation of the union, an employee cannot pursue grievance proce dures or even bring action before the courts for the enforcement of rights arising under the collective agreement. 5
As an exception to this rule, however, the courts have held that, where an employee has a patrimonial interest which is actually opposed to that of the union or of other members whose interests the union has chosen to espouse, such an employee has standing and is a necessary party to proceedings before the appropriate arbitral or other tribunal. The leading cases are:
Hoogendoorn v. Greening Metal Products and Screening Equipment Company et al., [1968] S.C.R. 30; Re Bradley and Ottawa Profes sional Fire Fighters Assn., [1967] 2 O.R. 311 (C.A.); and Appleton v. Eastern Provincial Airways Ltd., [1984] 1 F.C. 367 (C.A.).
In Hoogendoorn, union and company had signed a collective agreement calling for compulsory check off. Hoogendoorn refused to authorize such check off and a wildcat strike ensued. Union and company then agreed to submit to arbitration the question as to whether Hoogendoorn was obliged to authorize the check off or face discharge. Hoo- gendoorn was not given notice of the arbitration.
5 General Motors of Canada Ltd. v. Brunet, [1977] 2 S.C.R. 537.
Hall J., speaking for the majority of the Supreme Court, said, at page 39:
The arbitration proceeding was unnecessary as between the union and the company. Both fully understood and agreed that the collective agreement required Hoogendoorn to execute and deliver to the company a proper authorization form for deduc tion of the monthly union dues being paid by members of the union. Both the company and the union wanted him to do so. The arbitration proceeding was not necessary to determine that Hoogendoorn was required so to do. Both knew he was ada mant in his refusal. The proceeding was aimed at getting rid of Hoogendoorn as an employee because of his refusal either to join the union or pay the dues. It cannot be said that Hoogen- doorn was being represented by the union in the arbitration proceeding. The union actively took a position completely adverse to Hoogendoorn. It wanted him dismissed.
I can come to no other conclusion but that in the circum stances of this case it was improper for the learned arbitrator to proceed as he did in Hoogendoorn's absence. (Emphasis added.)
In Bradley, supra, the employer made certain promotions consistent with its interpretation of the seniority provisions of the collective agreement. The union disputed that interpretation and took the matter to arbitration on behalf of the employees who would otherwise have received those promotions. A necessary consequence of the union's position was that the first group of employees should lose the benefit of the promo tions they had obtained. The members of that group were not given notice of the arbitration proceedings. Laskin J.A., as he then was, speaking for the Ontario Court of Appeal, said, at pages 316 and 317:
A collective agreement is a unique legal institution because, despite the generality of its terms as part of a bargain made between a representative union and an employer, its existence and application result in personal benefits to employees who are covered by it. Once it is accepted, as it must be, that the benefits running to employees may differ according to job classification or seniority ranking (to take two illustrations), and that the representative union is put to a choice between employees who competed for the same preferment as to which it will support against a different choice made by the employer, substantive employment benefits of particular employees are put in issue and they are entitled to protect them if the union will not.
It follows that they are entitled to notice of arbitration proceedings taken to test their right to continued enjoyment of the benefits. The fact that particular provision for notice is not made either in the statute or in the collective agreement is of no moment. There is a large silence in both—and this is not
limited to collective bargaining relations in fire fighting—so far as concerns the procedure to be followed in an arbitration. The common law has been specially sensitive to deprivation of property or contractual advantages in proceedings of an adjudicative character without previous notice thereof to per sons likely to be directly affected, unless there is clear statutory exclusion of such notice. In the present case, there is none.
Bradley was specifically approved by the majority of the Supreme Court in Hoogendoorn.
Finally, in Appleton, supra, the employer, fol lowing the calling of a strike, had employed other persons to do the jobs of the striking employees. The union's position, in an unfair labour practices complaint before the Canada Labour Relations Board, was that the employer must reinstate the striking employees even though that might result in the displacement of the new employees. The Board accepted that position. Thurlow C.J., speak ing for the majority in this Court, said, at page 371:
Here the applicants, whether they were employees before the strike began or were hired after it began, were all members of the bargaining unit for which CALPA was the recognized bargaining agent. As members of the unit they would be bound by the collective agreement which the Board by its order established. Yet it is obvious that their interests were adverse to those espoused by CALPA. As members of the unit for whom CALPA acted they were, in my view, de facto parties and as persons against whose interest an order was to be made they were persons who ought to have been given an opportunity to become parties before such an order was made.
The other point that arises is whether as a matter of natural justice such pilots were entitled to notice and an opportunity to be heard before such an order was made. In my opinion, they were entitled to such an opportunity....
Returning to the facts of the present case, there can, in my mind, be no doubt that among the rights accruing to individual employees under the collective agreement was the right, under article 2.03, to opt out of dues check off.
There can be further no doubt that Parliament, by adopting the new text of section 162, which came into force July 18, 1984, has decided that it is not in the public interest that employees should be able to opt out of dues check off. A union need now only request a "Rand formula" clause to be
entitled to get it. Outside the internal politics of the union's conduct of its own affairs, an individu al employee has no status to contest the union's right to require a check off clause. A fortiori, if an individual is not a member of the union, there is no forum, domestic or otherwise, in which he may object.
The issue before the Board, therefore, was plain ly as to the date on which this important change in the rights of individual employees, a change, I repeat, that was decreed in the public interest, should take effect. The Board well understood this. At an early stage in the decision, it said:
In this case, it is the rights of the employees to revoke automat ic check-off of union dues deductions that is at the core of the employer's position regarding the effect of the proclamation of section 162 of the Code on July 18, 1984.
I should say as well (and this disposes of many of the arguments that were urged before us) that the issue was a real one, that it arose fairly in the context of the Board's hearing of the union's com plaint under section 184, that the Board had juris diction to enter upon the question and that the text of the new version of section 162 is one which would support a rational and bona fide decision in either sense. I, for one, would not have the temeri ty to suggest that a decision one way or the other is so patently unreasonable as to amount
... to a fraud on the law or a deliberate refusal to comply with it. 6
Thus there are two equally legitimate but dia metrically opposed possible interpretations of the effect of the new section 162. It was the Board's duty to pick between them. Clearly the union had an interest in promoting the interpretation which would have the new text apply to existing collec tive agreements. Who has an interest in promoting the opposite view? Surely not the employer. His only conceivable interest in opposing compulsory check off would be a desire to keep the party whom he must face across the collective bargain ing table in a state of financial weakness and insecurity. If that was ever a legitimate interest, it surely can no longer be so in the face of Parlia-
6 Syndicat des employés de production du Québec et de l'Acadie v. Canada Labour Relations Board et al., [1984] 2 S.C.R. 412, per Beetz J., at p. 420; (1985), 55 N.R. 321.
ment's clear statement of its view of the public interest.
The situation is different, however, for the employee who has exercised the option given to him under a valid collective agreement to revoke his dues check off. He surely has a vested right not to have his dues checked off. That right, to be sure, may be taken away by legislation but it seems to me impossible to deny him a legitimate interest in urging that the legislation is invalid or does not have the effect contended for by the union.
It will be recalled that, in the present case, the Board was dealing not only with the obligation to pay union dues in the future but with the retroac tive application of the Rand formula to wages already paid. It was a necessary consequence of the union's position that the employees were obliged to reach into their pockets to pay out sums of money which had not been deducted at source. In those circumstances, it seems to me to be beyond dispute that the interests of the union and those of the dissenting employees were directly opposed to one another.
To say that if the union and the employer had been ad idem on the proper interpretation of sec tion 162 they could together have executed an amendment to the collective agreement which would have the same result as the Board's order is nothing to the point. The two have not so agreed and the argument, in any event, begs the question as to the extent to which the union may affect the vested rights of individual employees during the currency of a collective agreement.
I conclude that the Board ought to have given notice to the employees prior to embarking on its enquiry.' Since the failure to give such notice was never waived and the resulting decision never rati-
' I would not, with respect, want to be taken as approving all that was said by Laskin J.A., as he then was, by way of obiter in the Bradley case, supra, with regard to the manner of giving notice. In particular, I do not think notice by personal service or registered mail is necessary. Section 13 of the Canada Labour Relations Board Regulations, 1978, (SOR/78-499), contains detailed rules permitting the posting of notices which would seem to me to be quite adequate to meet the requirements of the situation in this case.
fied by the affected employees, it follows that such decision must be set aside.
I would allow the section 28 application, set aside the decision under attack and return the matter to the Board for a new hearing and decision after proper notice to all interested parties.
HEALD J.: I concur. STONE J.: I agree.
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