The applicant, a non-profit environmental education centre, sought a declaration that its property was exempt from municipal taxation under section 3(1)5 of the Assessment Act as an 'educational seminary of learning'.
The respondent assessment corporation opposed the application, arguing the centre lacked a structured curriculum, regular students, and formal instructors.
The Superior Court of Justice granted the application, finding that the primary purpose of the centre, determined objectively, was educational.
The court held that a flexible approach to the definition of a 'seminary of learning' was appropriate, and the centre's workshops, symposiums, and experiential learning programs sufficiently constituted a focused educational agenda.
