The Restrictive Trade Practices Commission ordered several persons to appear before a Hearing Officer to give evidence in an inquiry under the Combines Investigation Act.
The Hearing Officer made rulings limiting the role of counsel, including denying the right to cross-examine witnesses, excluding a potential witness, and ruling that the Director need not disclose his reasons for commencing the inquiry.
The appellants sought to quash these rulings.
The Supreme Court of Canada dismissed the appeal, holding that the inquiry was purely investigatory and that neither the Act nor the common law doctrine of fairness required the Director to disclose his reasons or permitted counsel to cross-examine witnesses at this preliminary stage.