The applicant sought judicial review of the Registrar General's decision to cancel his birth registration under the Vital Statistics Act, following a criminal conviction where it was found he had assumed a false identity.
The applicant argued that delegating the decision to a Ministry lawyer created a reasonable apprehension of bias and that denying his request for a teleconference hearing breached procedural fairness.
The Divisional Court dismissed the application, finding no reasonable apprehension of bias given the distinct roles within the Ministry, and concluding that a written hearing satisfied the duty of fairness as the applicant failed to provide new evidence conclusively impeaching the prior judicial finding of his identity.
