The applicant appealed a decision denying a property tax exemption for its children's camp.
The application judge had found the camp was primarily recreational and did not qualify as a place for the 'care of children' under s. 3(1)11 of the Assessment Act.
The Divisional Court allowed the appeal, finding that the camp's primary purpose was the care of children in a special educational setting, integrating special needs children with others.
The court held that the application judge made a palpable and overriding error by failing to recognize the charitable and educational nature of the care provided.
