The appellant, a regional legal aid corporation, requested a business tax exemption for its legal aid bureau under the Act respecting Municipal Taxation.
The municipal commission refused the exemption, finding that professional legal services did not fall under the exemption for activities carried on mainly for social purposes.
The Supreme Court of Canada held that the commission's decision was patently unreasonable.
The Court found that the professional legal services offered by a legal aid bureau to economically underprivileged persons are inherently social in nature and clearly qualify for the business tax exemption under s. 236(5) of the Act.