Judgments

Decision Information

Decision Content

T-1787-81
Wilbert George Minott (Applicant)
v.
Presiding Officer of the Inmate Disciplinary Court of Stony Mountain Penitentiary and the Director of Stony Mountain Penitentiary (Respondents)
Trial Division, Nitikman D.J.—Winnipeg, April 1, 3 and 27, 1981.
Prerogative writs — Prohibition — Motion for order of prohibition to prevent continuation of hearing of charges against applicant by Inmate Disciplinary Court in the absence of counsel — Punishment for offences included loss of earned remission — Refusal of request for permission to have counsel present was based on a Commissioner's Directive — Whether Presiding Officer erred in law in his consideration of and failure to direct his mind to legal principles and requirements in the exercise of his discretion — Motion allowed — Peniten tiary Act, R.S.C. 1970, c. P-6, as amended, ss. 24.1(1), 29(1) — Penitentiary Service Regulations, C.R.C. 1978, Vol. XIII, c. 1251, ss. 38(1),(2), 38.1(1),(2), 39.
This is a motion by the applicant for an order of prohibition to prevent the continuation of the hearing of certain charges against the applicant by the Inmate Disciplinary Court in the absence of counsel. The applicant pleaded not guilty to charges of serious offences, the punishment for which included forfeit ure of earned remission credited or standing to his credit. A request for permission to have counsel represent him was denied on the basis of section 12a of the Commissioner's Directive 213. The applicant alleges that the Presiding Officer erred in his consideration of and failed to direct his mind to legal principles and requirements in the exercise of his discre tion when he refused the applicant's request for legal counsel.
Held, the motion is allowed. In arriving at his decision to deny counsel to the applicant, the Presiding Officer relied on, and placed undue emphasis on the Commissioner's Directive without giving proper consideration to the effect of sections 38(1) and (2)(b) and 38.1(1) and (2) of the Penitentiary Service Regulations. The Presiding Officer appears to have failed to address himself to the distinction between the Peniten tiary Service Regulations, which are "law" and the Commis sioner's Directive, which is not "law". Furthermore, there is nothing to suggest that the Presiding Officer gave any thought to the principle of fairness.
Martineau v. Matsqui Institution Disciplinary Board [1980] 1 S.C.R. 602, applied. Martineau v. Matsqui Insti tution Disciplinary Board -[1978] 1 S.C.R. 118, applied. Fraser v. Mudge [1975] 3 All E.R. 78, referred to. R. v. Visiting Justice at Her Majesty's Prison, Pentridge; Ex parte Walker [1975] V.R. 883, referred to. Dubeau v. National Parole Board [1981] 2 F.C. 37, referred to. In re
the R.C.M.P. Act and in re Husted [1981] 2 F.C. 791, referred to.
MOTION. COUNSEL:
Arne Peltz for applicant.
C. Henderson for respondents.
SOLICITORS:
Arne Peltz, Winnipeg, for applicant.
Deputy Attorney General of Canada for
respondents.
The following are the reasons for order ren dered in English by
NITIKMAN D.J.: This is a motion by the appli cant for an order of prohibition against the respondent Presiding Officer of the Inmate Disci plinary Court of Stony Mountain Penitentiary (hereinafter referred to as the Presiding Officer) and the Director of Stony Mountain Penitentiary from continuing or concluding the hearing of cer tain charges against the applicant (an inmate of Stony Mountain Penitentiary) under section 39 of the Penitentiary Service Regulations, C.R.C. 1978, Vol. XIII, c. 1251, as amended, in the absence of counsel, as requested by the applicant, or for such order as may be just.
The affidavit of the applicant sets out in part:
2. THAT I am an inmate in the Stony Mountain Penitentiary, presently serving a term of four years, one month and three days incarceration. At the present time I have remission stand ing to my credit in the total amount of 498 days, consisting of the following: 329 days of statutory remission, 4 days of earned remission, and 165 days of new earned remission. My mandato ry supervision release date is September 4th, 1981, according to calculations provided to me by the Stony Mountain Sentence Administrator.
3. THAT on March 18th, 1981, I was involved in certain incidents with living-unit officers, or guards, of the Stony Mountain Penitentiary. As a result, charges were laid against me under section 39 of the Penitentiary Service Regulations. I was charged with two counts of using threatening language to a guard, and one count of failing to obey a lawful order of a penitentiary officer.
4. THAT immediately after the said incidents, an administrative decision was made under section 40 of the Penitentiary Service
Regulations placing me in solitary confinement pending the hearing of the charges against me.
5. THAT on March 20th, 1981, I appeared before the Presiding Officer of the Disciplinary Court. I entered pleas of not guilty. The case was remanded for one week so that the living-unit officers involved could be present to give evidence against me. In addition, I indicated to the Disciplinary Court that I had two witnesses that I wished to call on my own behalf, although one of the witnesses was an inmate due for release very shortly.
6. THAT following my appearance in Disciplinary Court, I was returned to solitary confinement. I then made a request to see the Legal Aid Manitoba duty counsel who attends at the Penitentiary.
7. THAT on March 24th, 1981, the duty counsel arrived at the Penitentiary and interviewed me about the charges. I signed an application for legal aid representation before the Disciplinary Court.
8. THAT on Thursday, March 26th, 1981, I met with Arne Peltz, who advised me that he had been appointed the previous day by the Area Director of Legal Aid Manitoba to represent me with respect to the charges. My counsel advised me that he had made a request to the Presiding Officer of the Disciplinary Court for permission to appear and make representations in support of my right to have counsel present at the actual hearing and determination of the charges, but that this request had been denied.
9. THAT in the afternoon of March 26th, 1981, I appeared again in the Disciplinary Court. I presented to the Presiding Officer a written request that my counsel be permitted to appear with me at the hearing. Attached hereto and marked as Exhibit 'A' to this my Affidavit is a true copy of the document I presented. The original copy was signed by me and is in the hands of the Disciplinary Court.
10. THAT I also presented to the Court a letter, a copy of which is attached hereto and marked as Exhibit 'B' to this my Affidavit, which stated as follows:
I am pleading not guilty to the charge of threatening a guard.
I have been held in segregation since March 18, 1981. I request permission to be released pending the full hearing of my charge, for these reasons:
(1) I am not a danger to anyone in the Institution.
(2) I have at least one witness for my defence, I need to prepare with him.
(3) I have already served 8 days in custody. Maximum punishment is only 30 days.
(4) I wish to have my lawyer present. I understand it will take several days to arrange for a decision on the right to counsel.
(5) Even if my lawyer cannot be present, I wish to review the charge sheets with him before the hearing. When I received these, I was upset and threw them away. My lawyer says he wishes to discuss them with me, and I have no copy of the charge sheets.
Thank you for considering my request.
My lawyer is Arne Peltz, Legal Aid Manitoba, 943-0491.
11. THAT the Presiding Officer read to me an excerpt from the Commissioner's Directives dealing with an inmate's right to have counsel present at such hearings, and stated that as a result of this Directive, my request must be refused.
13. THAT the hearing is scheduled to resume on the afternoon of April 3rd, 1981, at which time evidence is to be taken. I wish to have my legal counsel present at that time to advise, assist and represent me. This case will involve oral testimony from a number of witnesses and I expect that there will be serious conflicts in the evidence. I have no experience in representing myself in legal or similar proceedings, and I therefore believe that in the circumstances of my case, I require legal counsel in order to test the evidence against me and present evidence on my own behalf. I further believe that I will not be capable of making a proper argument on the evidence after the conclusion of the testimony. In the event that I should be found guilty of the charges, I further believe that I require legal counsel to speak on my behalf on the question of what sentence should be imposed.
14. THAT the particulars of the offences, as provided to me by officers of the Institution, indicate that the charges against me are not merely minor or trivial matters. It is alleged that I used obscene and threatening language to Penitentiary officers. It is further alleged that I made a threat to take some type of action against one of the officers after my release from prison. It is further alleged that I refused a direct order and had to be forcibly restrained. Finally, it is alleged that I am "non-produc tive" in the Institution, a classification which results in loss of a number of privileges.
Exhibit "A", referred to in paragraph 9 of the applicant's affidavit, reads:
Mr. C. Lorenc
Chairman
Inmate Disciplinary Court Stony Mountain Penitentiary, Municipality of Rockwood, Manitoba
Dear Sir:
This is to request that my legal counsel be permitted to be present in order to advise and assist me at the hearing of the institutional charge against me.
DATED March 26th, 1981.
W. G. MINOTT
The grounds relied on in the notice of motion are:
1. THAT the PRESIDING OFFICER of the said Inmate Discipli nary Board, in refusing or neglecting to allow the presence of the Applicant's legal counsel at the hearing of the charges against the Applicant, acted in excess of jurisdiction and con trary to law, and further, that the said PRESIDING OFFICER proposes to continue acting in excess of jurisdiction and con trary to law by resuming the said hearing on April 3rd, 1981 in the absence of the Applicant's legal counsel.
2. THAT the PRESIDING OFFICER Of the said Inmate Discipli nary Board, in refusing the Applicant's request to have legal counsel present, relied on a standing policy of the Commission er of Corrections, as set forth in Commissioner's Directive 213, and did not direct his mind to the particular circumstances of the case at hand, thereby neglecting or refusing to exercise his discretion according to law and fettering his discretion.
3. THAT in the circumstances of this case, the said PRESIDING OFFICER has denied and, will deny to the Applicant a fair hearing of the charges against him in accordance with the principles of fundamental justice as set forth in section 2(e) of the Canadian Bill of Rights, R.S.C. 1970, or in the alternative, the said Respondent has denied and will deny to the Applicant his right to a determination of the charges against him in accordance with the common law duty of fairness.
A further application in the notice of motion is for:
... an order of mandamus, directing the Respondent DIRECTOR OF STONY MOUNTAIN PENITENTIARY to permit the presence of the Applicant's legal counsel at the said hearing ...
but this portion of the notice of motion, while not abandoned, was not pressed for at the hearing, the applicant relying instead on the argument that the Presiding Officer erred in his consideration of and failed to direct his mind to legal principles and requirements in the exercise of his discretion when he refused applicant's request for legal counsel.
The affidavit of Christopher Walter Lorenc, of
the City of Winnipeg, in Manitoba, Barrister-at- law, reads in part:
1. I am the person appointed by the Solicitor General pursuant to Penitentiary Service Regulation No. 2.28, paragraph [38.1](1), to be the Presiding Officer of the Inmate Discipli nary Court of Stony Mountain Penitentiary, and as such have personal knowledge of the matters hereinafter deposed to by me.
2. In answer to paragraph 8 of the Affidavit of the Applicant, thé request of Arne Peltz, as counsel for the Applicant, to appear was not denied by me as I do not have the authority to admit persons to the Stony Mountain Penitentiary.
3. In further answer to paragraph 8 aforementioned I (sic) was agreed by me and Arne Peitz that the matter would be adjourned for one week to allow him time to make whatever application he deemed appropriate in the circumstances.
4. In answer to paragraph 11 of the Affidavit of the Applicant, I based as a source for my decision the Penitentiary Act, its regulations thereunder, Commissioner's Directive No. 213 and Annex 'A' to the aforementioned Commissioner's Directive.
The Penitentiary Act, R.S.C. 1970, c. P-6, as amended, under section 24.1(1) provides for for feiture, in whole or in part, of earned remission credited or standing to his credit, on conviction by a disciplinary court of any disciplinary offence (of an inmate).
Dealing with Rules and Regulations under the Penitentiary Act (Regulations), section 29(1) of the Act reads in part:
29. (1) The Governor in Council may make regulations
(b) for the custody, treatment, training, employment and discipline of inmates;
(3) Subject to this Act and any regulations made under subsection (1), the Commissioner may make rules, to be known as Commissioner's directives, for the organization, training, discipline, efficiency, administration and good government of the Service, and for the custody, treatment, training, employ ment and discipline of inmates and the good government of penitentiaries. [Emphasis added.]
Section 38(1) and (2), of the Regulations headed Inmate Discipline, reads in part:
38. (1) The institutional head of each institution is respon sible for the disciplinary control of inmates confined therein.
(2) No inmate shall be punished except pursuant to
(a) an order of the institutional head or an officer designated by the institutional head; or
(b) an order of a disciplinary court. [Emphasis added.]
Section 38.1(1) and (2) reads:
38.1 (1) The Minister may appoint a person to preside over a disciplinary court.
(2) A person appointed pursuant to subsection (1) shall
(a) conduct the hearing;
(b) consult, in the presence of the accused inmate, with two officers designated by the institutional head;
(c) determine the guilt or innocence of an accused inmate appearing before him; and
(d) on finding an accused inmate guilty, order such punish ment authorized by these Regulations as he deems suitable.
Section 39, headed Inmate Offences, reads in part:
39. Every inmate commits a disciplinary offence who
(a) disobeys or fails to obey a lawful order of a penitentiary officer,
(g) is indecent, disrespectful or threatening in his actions, language or writing toward any other person,
I move next to Commissioner's Directive No. 213, "Guidelines for Inmate Discipline".
Section 7 of the Directive, dealing with "Deter- mination of Category of Offence", while providing in paragraph "a":
7....
a. The guidelines defining an offence as either serious/flagrant or minor are not intended to restrict the discretion of the institutional director or the officer designated by him, in determining the category of offence. Each case shall be assessed according to its own merits depending on the cir cumstances surrounding the incident.
provides in paragraph "b" that serious or flagrant offences shall normally include the case of an inmate who (and I list only those pertinent here):
b....
(1) assaults or threatens to assault another person;
(9) disobeys or fails to obey a lawful order of a penitentia ry officer;
(11) is indecent, disrespectful, or threatening in his actions, language, or writing, towards any other person;
Paragraph "c" provides that minor offences shall normally include the case of an inmate who:
c....
(1) leaves his work without the permission of a penitentia ry officer;
(2) fails to work to the best of his ability;
(3) wilfully disobeys or fails to obey any regulation or rule governing the conduct of inmates.
Section 8, headed "Types of Punishment", pro vides that if an inmate is found guilty of a serious or flagrant offence, punishments shall consist of one or more of the following (and again I list only those punishments I consider pertinent here), these being:
8....
(1) forfeiture of statutory remission;
(2) dissociation for a period not exceeding thirty days, with the normal diet;
(3) loss of privileges;
(4) forfeiture of earned remission;
In Annex "A" to Commissioner's Directive No. 213, 1979-05-17, headed "Administrative Proce-
dures at Hearings for Serious or Flagrant Offences", section 12, headed "Miscellaneous", provides in part:
12....
a. Occasions have arisen where an accused has made formal or informal demands that he be represented by counsel. Such demands shall be met with the response that he is not entitled to counsel, and that the hearing will proceed without the accused person being represented.
It is clear from the material filed that the offences which the inmate is charged with, are categorized as serious and flagrant, and it would follow that by reason of the seriousness and fla- grancy of the alleged offences, that the provisions of sections 38(1) and (2)(b) and 38.1(1) and (2) were invoked and a hearing by a disciplinary court was directed.
Annex "A" to Commissioner's Directive No. 213 sets out administrative procedures at hearings for serious or flagrant offences, making provision inter alia for taking pleas, calling witnesses, both for prosecution and defence, and further sets out that technical rules of evidence in criminal matters do not apply in such disciplinary hearings.
I have already referred to section 12 of Directive No. 213. Counsel for applicant argued that this Directive, which, in effect, is no more than an administrative decision, is ineffective as being overridden by sections 38(2)(b) of the Regula tions, which refers to punishment by a disciplinary court, as was ordered in this case, and 38.1(1) and (2) of said Regulations, which provide for the appointment by the Minister of a person to preside over a disciplinary court and how the hearings shall proceed. I believe this argument to be well founded, and I agree with it.
In Martineau v. Matsqui Institution Discipli nary Board [ 1980] 1 S.C.R. 602, (commonly referred to as Martineau No. 2), Pigeon J., dealing with the dismissal of the appeal to the Supreme Court of Canada in Martineau v. Matsqui Institu tion Inmate Disciplinary Board [1978] 1 S.C.R. 118 (commonly referred to as Martineau No. 1), which was an appeal to the Supreme Court of Canada, while Martineau No. 2 dealt with the right to certiorari, at pages 631-632 said:
In view of the wording of s. 28, the affirmation of the denial of judicial review means that it was determined that the disciplinary sentence in question was "a decision or order of an administrative nature not required by law to be made on a judicial or quasi-judicial' basis". The reasons of the majority, except one judge who agreed with the reasons of the Court of Appeal, show that, in their view, the "Directives" governing the procedure for dealing with disciplinary offences were con sidered to be administrative directions rather than "law", although the Regulations defining disciplinary offences and specifying the penalties that may be inflicted by the penitentia ry authorities were in the nature of law.
and in Martineau No. 2, Dickson J., as well as dealing with the dismissal of the appeal to the Supreme Court of Canada, reported in Martineau No. 1, said at page 609:
This Court, by a majority, dismissed the further appeal: Mar- tineau and Butters v. The Matsqui Institution Inmate Discipli nary Board ([1978] 1 S.C.R. 118) (hereinafter referred to as Martineau (No. 1)). The Court held that the impugned order was not within the scope of the opening words of s. 28 of the Federal Court Act and that the Directive of the Commissioner of Penitentiaries - was not "law" within the meaning of the phrase "by law" in s. 28. [Emphasis added.]
As well, in Martineau No. 1, after quoting the provisions of section 13 of Directive No. 213, dealing with the hearing of charges for serious or flagrant offences, Pigeon J., at page 128, said:
There remains, however, the question whether the directive is to be considered as "law" within the wording of s. 28. In this connection, it is necessary to consider the effect of s. 29 of the Penitentiary Act, R.S.C. 1970, c. P-6:
29. (1) The Governor in Council may make regulations
(a) for the organization, training, discipline, efficiency, administration and good government of the Service;
(b) for the custody, treatment, training, employment and discipline of inmates; and
(c) generally, for carrying into effect the purposes and provisions of this Act.
(2) The Governor in Council may, in any regulations made under subsection (1) other than paragraph (b) thereof, pro vide for a fine not exceeding five hundred dollars or impris onment for a term not exceeding six months, or both, to be imposed upon summary conviction for the violation of any such regulation.
(3) Subject to this Act and any regulations made under subsection (1), the. Commissioner may make rules, to be known as Commissioner's directives, for the organization, training, discipline, efficiency, administration and good gov ernment of the Service, and for the custody, treatment, training, employment and discipline of inmates and the good government of penitentiaries.
I have no doubt that the regulations are law. [Emphasis added.]
I do not think the same could be said of the Directives. They are clearly of an administrative and not a legislative nature.
I have not overlooked the decisions in Fraser v. Mudge [1975] 3 All E.R. 78, and R. v. Visiting Justice at Her Majesty's Prison, Pentridge; Ex parte Walker [ 1975] V.R. 883 (Supreme Court of Victoria), in both of which cases the refusal to legal representation was upheld.
And while the decision in Mudge, supra, was accepted by Pigeon J. in Martineau No. 2, he did say, at page 637:
However, this does not mean that the duty of fairness may not be enforced by the Trial Division through the exercise of the discretionary remedies mentioned in s. 18 of the Federal Court Act. [Emphasis added.]
In Mudge, one of the guiding considerations appeared to be that the case be decided quickly. At page 79 Lord Denning M.R. put it thusly:
We all know that, when a man is brought up before his commanding officer for a breach of discipline, whether in the armed forces or in ships at sea, it never has been the practice to allow legal representation. It is of the first importance that the cases should be decided quickly. If legal representation were allowed, it would mean considerable delay. So also with breaches of prison discipline. Those who hear the cases must, of course, act fairly. They must let the man know the charge and give him a proper opportunity of presenting his case. But that can be done and is done without the matter being held up for legal representation. I do not think we ought to alter the existing practice. We ought not to create a precedent such as to suggest that an individual is entitled to legal representation. There is no real arguable case in support of this application and I would reject it. [Emphasis added.]
In the within case, section 38.1(1) of the Peni tentiary Service Regulations provided for a hear ing before a person appointed to preside over a disciplinary court and to conduct the hearing in the manner earlier set out.
In his affidavit, Bill Merrett, of the City of Winnipeg, in the Province. of Manitoba, Barrister
and Solicitor, deposes that he is the Assistant to the Area Director of Legal Aid Manitoba, so employed since 1977, with duties involving, inter alia, administration of duty counsel services of Legal Aid Manitoba.
He further deposes:
3. THAT I am advised that the Disciplinary Court at Stony Mountain Institution sits approximately once per week to hear charges against inmates. I am further advised that where an inmate pleads not guilty, the case is often remanded to enable prosecution and defence witnesses to attend, or to allow other preparations for the case.
4. THAT in my opinion, given the staff resources of Legal Aid Manitoba and our procedures with respect to the duty counsel program, Legal Aid Manitoba could meet requests for inmate representation at Disciplinary Court without disrupting the existing operations of that Court.
It is my understanding that Mr. Arne Peltz, who requested to appear as counsel for the applicant, was ready to proceed with his defence of the charges against the applicant and his acting as counsel of aforesaid applicant should not have entailed any appreciable delay in the hearing.
At this time I should mention that the hearing has been adjourned to April 30th next to permit time for an order herein to be made.
It is my considered opinion that section 12a of Annex "A" of Commissioner's Directive No. 213 cannot, as Pigeon J. said in Martineau No. 1, be considered as "law", and since the Penitentiary Service Regulations are "law", section 38.1(1) and (2), which sets out the manner of hearing of the disciplinary court, must govern and override the provisions of section 12a, Annex "A" of Com missioner's Directive No. 213. Accordingly I hold that said provision 12a is ultra vires in so far as a hearing before a disciplinary court is concerned.
I turn next to the question of fairness in the exercise of discretion by the Presiding Officer in deciding whether or not counsel should be permit ted to represent the applicant.
In Martineau No. 2, Dickson J. considered the question of fairness and dealt with it at some
length and, if I may say with respect, in a most cogent, rational and compelling manner. At pages 629 and 630 he put it thusly:
4. An inmate disciplinary board is not a court. It is a tribunal which has to decide rights after hearing evidence. Even though the board is not obliged, in discharging what is essentially an administrative task, to conduct a judicial proceeding, observing the procedural and evidential rules of a court of law, it is, nonetheless, subject to a duty of fairness and a person aggrieved through breach of that duty is entitled to seek relief from the Federal Court, Trial Division, on an application for certiorari. [Emphasis added.]
and continuing on pages 630 and 631, he said:
7. It is wrong, in my view, to regard natural justice and fairness as distinct and separate standards and to seek to define the procedural content of each. In Nicholson, the Chief Justice spoke of a "... notion of fairness involving something less than the procedural protection of the traditional natural justice". Fairness involves compliance with only some of the principles of natural justice. Professor de Smith, (Judicial Review of Administrative Action, 3rd ed. 1973, p. 208) expressed lucidly the concept of a duty to act fairly:
In general it means a duty to observe the rudiments of natural justice for a limited purpose in the exercise of functions that are not analytically judicial but administra tive.
The content of the principles of natural justice and fairness in application to the individual cases will vary according to the circumstances of each case, as recognized by Tucker L.J. in Russell v. Duke of Norfolk ([1949] 1 All E.R. 109), at p. 118.
8. In the final analysis, the simple question to be answered is this: Did the tribunal on the facts of the particular case act fairly toward the person claiming to be aggrieved? It seems to me that this is the underlying question which the courts have sought to answer in all the cases dealing with natural justice and with fairness.
In a decision of Addy J. [In re the Royal Canadian Mounted Police Act and in re Husted [1981] 2 F.C. 791] delivered February 5, 1981, the learned Trial Judge set out the facts and issue as follows [at page 793]:
The applicant, Husted, a special constable, is charged under paragraph (a) of section 25 of the Royal Canadian Mounted Police Act, R.S.C. 1970, c. R-9, of the major service offence of refusing to obey a lawful command to hand over a firearm. The applicant, Ridley, who holds the rank of corporal, stands charged at the same time of another major service offence under section 25(o) of disgraceful conduct in pointing a revolv er at or toward a constable.
Both offences were allegedly committed on the same day, namely 5 January 1980, that is some eleven months before formal charges were laid on 7 November 1980.
After referring to arguments of counsel and setting out the sections under which the applicants were respectively charged, he continued [at pages 793-794]:
The facts are uncontradicted. When the accused appeared for their trials before Superintendent J. M. Roy they had both retained and instructed the same counsel who was not a member of the Force but who was present outside of the room where the trial was scheduled to be held. They both requested that they be tried together and that he be allowed to represent them. Neither of the applicants had any formal legal training. Their request was denied by the service court and an adjourn ment was granted the accused on the grounds that they were not prepared to proceed at that time. Before the date of resumption of the proceedings the present applications were launched.
The controversy arises over the application or, more precise ly, over the validity of section 33 of the Royal Canadian Mounted Police Regulations, C.R.C. 1978, Vol. XV, c. 1391, issued pursuant to section 21 of the Act. Section 33 of the Regulations reads as follows:
33. No member whose conduct is being investigated under section 31 of the Act or who is charged with any offence described in section 25 or 26 of the Act is entitled to have professional counsel appear on his behalf at that investigation or trial.
Section 21(1) of the Act reads as follows:
21. (1) The Governor in Council may make regulations for the organization, training, discipline, efficiency, adminis tration and good government of the force and generally for carrying the purposes and provisions of this Act into effect.
Further in his judgment [at page 795], he stated:
There is no absolute common law right to counsel in all cases where an individual is subject to some penalty. The courts have consistently refused to intervene on the grounds that represen tation by counsel was denied in certain service disciplinary matters where the hearing is, by nature of the subject-matter or the alleged offence, of an internal administrative nature and concerns a disciplinary matter within a special body such as a branch of the armed services or a police organization.
And further in his judgment, after pointing out that the hearing is usually held in a very informal manner without a court stenographer recording the proceedings and without regard to the strict rules of evidence, he said that in some cases the law specifically prohibits the employment of out side agencies or counsel since the exigencies of the service require this degree of informality to pre vent day-to-day administration of the Force and the maintenance of discipline becoming so cumber some and time-consuming as to be ineffective.
But then he added:
On the other hand, the common law recognizes that wherever a person's liberty or livelihood is at stake in a legal trial, he should not unreasonably be deprived of the services of the duly qualified legal counsel of his choice unless the employment of any particular counsel would unduly delay or impede the administration of justice. It is a natural corollary of the princi ple that an accused is entitled to a full and fair defence. [Emphasis added.]
And later in his judgment, he said this [at page 797]:
It would be nothing short of ludicrous to expect an ordinary layman, without the benefit of legal counsel, to either under stand, abide by or, more importantly, benefit by the rules of evidence in criminal matters such as the rules regarding state ments and admissions made to persons in authority.
In Dubeau v. National Parole Board [ 1980] 6 W.W.R. 271 [[1981] 2 F.C. 37], a case heard by Smith D.J. (Federal Court of Canada, Trial Divi sion), the headnote reads:
The accused breached a condition of his parole by applying for credit without the permission of his parole officer. He had a disciplinary interview with his parole officer and as a result signed an undertaking not to apply for credit without permis sion. On that same day he was arrested and charged with several criminal offences, to which he pleaded not guilty. The offences were unrelated to the credit applications. Two weeks later his parole was suspended. He applied for a post-suspen sion hearing, and at the hearing the board questioned him about the pending criminal charges and refused to allow his counsel to attend. The board's reasons for revocation were based on the breach of conditions, not the pending charges. The accused applied for certiorari claiming that the board had erred by considering the criminal charges and had acted unfairly by not allowing his counsel to be present.
Held—Application for certiorari granted; revocation of parole quashed.
The court had jurisdiction to review the hearing as the board was under a duty to act fairly.
While the board had very wide powers and could consider all the circumstances, it was arguable that the board should not have questioned the accused about the criminal charges.
Further, to refuse to allow the accused to have counsel present at the hearing was unfair.
The judgment is lengthy and I propose to quote only two paragraphs at page 288 [pages 55-56 of the Federal Court Reports], which read:
My conclusion is that in view of all the circumstances outlined supra, and notwithstanding the Board's absolute dis cretion to revoke or not revoke the applicant's parole, it is at least arguable that its members should not have questioned him about the criminal charges. If that argument is not maintain able, it is nevertheless my view that to refuse to allow him to have legal counsel present during the hearing was unfair treat ment of the applicant.
I am mindful also of the fact that the primary purpose of certiorari is to see that minor tribunals conduct their hearings correctly and fairly. This purpose has been stated to be even more important than that of protecting individual rights.
I have already referred to the affidavit of the respondent Presiding Officer. I refer again to para graph 4 thereof, where he states that in answer to paragraph 11 of the applicant's affidavit (which reads "That the Presiding Officer read to me an excerpt from the Commissioner's Directives deal ing with an inmate's right to have counsel present at such hearings, and stated that as a result of this Directive, my request must be refused."), ". .. I based, as a source for my decision, the Penitentia ry Act, its Regulations thereunder, Commission er's Directive No. 213, and Annex 'A' to the aforementioned Commissioner's Directive."
Reading paragraph 4 of the Presiding Officer's affidavit and paragraph 11 of the applicant's affidavit, I have the distinct feeling that in arriving at his decision to deny counsel to the applicant, the Presiding Officer relied on, and placed undue emphasis on the Commissioner's Directive Annex "A", section 12, without giving proper consider ation to the effect of section 38(1) and (2)(b) and section 38.1(1) and (2) of the Penitentiary Service Regulations and Rules on said Commissioner's Directive, Annex "A", section 12.
I have not overlooked the Presiding Officer's statement in his affidavit that he based his deci sion, as well, on the Penitentiary Act and its Regulations thereunder, but I am still of the opin ion that he appears to have failed to address himself to the distinction between the Penitentiary Service Regulations, which are "law" and the Commissioner's Directive, section 12, already referred to, which is not "law".
Furthermore, there is nothing in the material to suggest that in arriving at his decision, the Presid ing Officer gave any thought to the principle of fairness, a principle which was strongly empha sized by Pigeon J., in Martineau No. 1 and by Dickson J., in Martineau No. 2 and, as well, by Addy J., in Ridley and Smith D.J., in Dubeau, all supra.
It is my opinion that the decision of the Presid ing Officer is a discretionary one, and I recognize this discretion should not be interfered with unless it was not judicially exercised. With respect, I believe such was the case here, and I, accordingly, remit the matter to the Presiding Officer for reconsideration of his decision, giving due thought and attention to the effect of sections 38(1) and (2)(b) and 38.1(1) and (2) and their legal effect on Commissioner's Directive No. 213, Annex "A", section 12; and what I consider of marked impor tance, the question of fairness to the applicant.
After review and consideration of the facts and giving effect to the law, as set out in these reasons, the Presiding Officer is entitled to exercise his discretion in whatever way he decides is legally correct.
There will be no costs.
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.