The appellant municipality challenged the federal minister's valuation of lands at a national historic site for payments in lieu of municipal property taxes.
The Court held that, while the minister may form an independent opinion of property value, that opinion must reflect how an assessment authority would value the property under the applicable tax system and must remain consistent with the governing statute's fairness objectives.
The Court found the nominal valuation approach unreasonable because it lacked evidentiary grounding in assessment practice and effectively undermined the statutory scheme's inclusion of historic sites.
The appeal was allowed and the matter was remitted for redetermination by the minister, with any new advisory panel required to be differently constituted.
