The Municipal Property Assessment Corporation appealed a Divisional Court decision granting a property tax exemption to a non-profit children's camp operated by the Diocese of Toronto Camps.
The camp claimed exemption under the Assessment Act as land used for 'the care of children'.
The Court of Appeal allowed the appeal and restored the application judge's finding that the primary purpose of the camp was recreational, not the care of children.
The Court held that 'care of children' in the statutory context refers to physical aspects of care such as protection, shelter, and nourishment, which were incidental to the camp's primary recreational purpose.
