James Sayre

The complainant workers suffered from chronic pain and received a fixed compensation award from the Workers' Compensation Board.

They appealed to the Board's Review Division, arguing the policy was discriminatory under the Human Rights Code.

The Review Officer concluded the policy was not discriminatory.

Instead of seeking judicial review, the complainants filed new complaints with the Human Rights Tribunal.

The Tribunal refused to dismiss the complaints under s. 27(1)(f) of the Code.

The Supreme Court of Canada held that the Tribunal's decision was patently unreasonable because it ignored the principles of finality and the rule against collateral attack, effectively allowing the relitigation of an issue already decided by a decision-maker with concurrent jurisdiction.

The appellant, a 30-year-old able-bodied widow without dependent children, was denied survivor's benefits under the Canada Pension Plan because she was under the age of 35.

She challenged the age-based eligibility criteria as discriminatory under s. 15(1) of the Charter.

The Supreme Court of Canada dismissed the appeal, establishing a comprehensive three-step framework for equality analysis.

The Court held that while the legislation drew a distinction based on the enumerated ground of age, it did not violate the appellant's essential human dignity, as the provisions were ameliorative in nature and corresponded to the actual long-term needs and circumstances of older surviving spouses.