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Farm stabilization appeal dismissed; good faith and contractual fairness standards were satisfied.
In an appeal by agricultural producers challenging compensation calculations under a provincial farm income stabilization program, the Court held the program is an innominate contract governed by general private law principles rather than insurance contract rules.
The governing standards for performance of contractual powers were good faith and contractual fairness, interpreted in light of the program’s public-interest objective.
The Court found no reversible error in the trial findings upholding the methodology used in the economic and statistical study for 2006 to 2008 compensation.
Arguments based on reasonable expectations and alleged methodological flaws did not justify appellate intervention.
Program operator could use collective linkage under the contract's interpretation framework.
This appeal concerned whether Quebec's farm income stabilization program is a contract and how compensation-linkage decisions under section 88(3) must be interpreted.
The Court held the program is an innominate administrative contract, not a contract of insurance, and interpreted the text and structure as granting discretion over collective linkage.
Applying contractual good-faith and fairness principles, the majority found the respondent's collective methodology lawful in the circumstances.
The dissent would have allowed the appeal in part, concluding the linkage approach breached contractual limits by attributing notional amounts disconnected from participants' actual entitlements.
