Edgar Sexton

The appellant appealed a decision regarding the calculation of an award for future care.

The sole issue was whether the court could take the impact of taxation into account when calculating the amount of the award.

Following the reasoning in Watkins v. Olafson, the Supreme Court of Canada held that the impact of taxation may be considered.

The appeal was allowed and the matter remitted to the Supreme Court of British Columbia to determine the amount to be added for taxation.

The Restrictive Trade Practices Commission ordered several persons to appear before a Hearing Officer to give evidence in an inquiry under the Combines Investigation Act.

The Hearing Officer made rulings limiting the role of counsel, including denying the right to cross-examine witnesses, excluding a potential witness, and ruling that the Director need not disclose his reasons for commencing the inquiry.

The appellants sought to quash these rulings.

The Supreme Court of Canada dismissed the appeal, holding that the inquiry was purely investigatory and that neither the Act nor the common law doctrine of fairness required the Director to disclose his reasons or permitted counsel to cross-examine witnesses at this preliminary stage.