Judgments

Decision Information

Decision Content

A-869-88
In the Matter of the Canada Labour Code And in the Matter of the State Immunity Act
And in the Matter of a Reference by the Canada Labour Relations Board pursuant to subsection 28(4) of the Federal Court Act
INDEXED AS: CANADA LABOUR CODE (CAN.) (RE) (CA.)
Court of Appeal, lacobucci C.J., Mahoney and Stone JJ.A.—Ottawa, June 13 and August 9, 1989.
International law — Sovereign immunity — U.S.A. claiming immunity under State Immunity Act, s. 3 with respect to certification application filed by Union on behalf of Canadian civilians employed at its naval base at Argentia, Newfound- land — Foreign state cannot claim immunity if explicit waiver of right to sovereign immunity or if proceedings relating to commercial activity of foreign state — Subscription to North Atlantic Treaty Status of Forces Agreement not explicit sub mission to jurisdiction of Canadian courts — Implicit in definition of "commercial activity" that one look to nature of activity rather than to purpose — Certification proceeding involving contracts of employment, entry into which commer cial in nature — Result disturbing as could mean loss of dignity if foreign state compelled by domestic tribunal to bargain over conditions of employment — Problem avoidable by legislative amendment.
Labour relations — Union seeking certification as bargain ing agent for Canadian civilians employed at American naval base in Newfoundland — Certification proceedings conduct "relating to any commercial activity" of foreign state — U.S.A. precluded from claiming state immunity by State Immunity Act, s. 5.
This was a reference to determine whether the Canada Labour Relations Board erred in finding that the United States of America could not claim state immunity under section 3, State Immunity Act with respect to an application for certifica tion filed on behalf of Canadian civilians employed by the U.S. Department of Defence at its military base at Argentia, New- foundland. Some 60 Canadians work at the base as firefighters and maintenance personnel. The Union sought certification under the Canada Labour Code as bargaining agent for those employees. A foreign state is immune from the jurisdiction of any court in Canada (State Immunity Act, section 3), except when it waives immunity by explicitly submitting to the juris diction of the court (section 4), or if the proceedings relate to any commercial activity of the foreign state (section 5). "Com- mercial activity" is defined as any conduct that by reason of its nature is of a commercial character. The Board applied the commercial activity test developed by American courts (if the
activity is one in which a private person could engage, it is not entitled to immunity) and found that the contract of employ ment constituted a commercial activity. The issues were wheth er the U.S.A. had waived immunity and, if not, whether the certification proceeding was a commercial activity. The Union argued that the U.S.A. had waived immunity by signing the 1951 North Atlantic Treaty Status of Forces Agreement, which provides that local civilian labour requirements shall be satis fied in the same way as the comparable requirements of the receiving state.
Held, state immunity could not be claimed.
Per lacobucci C.J. (Stone J.A. concurring): Signing the North Atlantic Treaty Status of forces Agreement did not amount to explicit submission to the jurisdiction of Canadian courts.
The reference in the definition of "commercial activity" to any transaction, act or conduct that by reason of its nature is of a commercial character suggests a narrower scope for immuni ty than if it referred to the purpose of the activity. The American definition expressly mentions the nature of the course of conduct, but continues "rather than by reference to its purpose". The Canadian definition implicitly conveys the same meaning, i.e. one looks to the nature of the transaction or activity, not to its purpose. Looking to purpose would tend to introduce a recognition of the wider net of immunity afforded under the traditional absolute theory, which could lead to defeating the statutory objective of adopting a restrictive approach to immunity as reflected in the State Immunity Act. The nature of the transaction (employment contracts) was commercial and the certification proceedings before the Board related to that commercial activity within section 5 of the State Immunity Act. Although the purpose of the employment con tracts was to further state or public objects of the United States by operating a naval base, the Act does not countenance the purpose of the state's activity but rather compels focus on the nature of the alleged commercial activity.
Per Mahoney J.A. (Stone J.A. concurring): In recent years there has been a move away from absolute sovereign immunity from the jurisdiction of common law courts to a more restric tive concept. Canada, the U.S.A. and Great Britain codified that restrictive concept more or less contemporaneously. The British legislation by its terms, and the American legislation by externally stated legislative intent exclude sovereign immunity in respect of employment of their citizens or residents within their territories by foreign states. American courts have been given effect to that legislative intent. Contracts for the pur chase of goods or services and contracts of employment should receive the same treatment for the purposes of the State Immunity Act. A certification proceeding relates to the employment of members of the proposed bargaining unit under contracts of service, entry into which is conduct of a commer cial character on the part of the U.S.A. Invocation of state immunity in this case could be rationalized only if one looked
beyond the nature of the employment to its broad purpose—to serve American defence requirements.
This conclusion was disturbing in that the sovereign dignity of a foreign state could be compromised if a domestic tribunal can compel it to bargain over conditions of employment and impose those conditions. The rationale behind state immunity is the avoidance of embarrassment of functions and loss of digni ty. That problem was, however, outside the narrow scope of this reference. Parliament would have to amend the State Immuni ty Act if Board jurisdiction in cases such as this is to be abrogated.
STATUTES AND REGULATIONS JUDICIALLY CONSIDERED
Agreement between the Parties to the North Atlantic Treaty regarding the status of their forces, June 19, 1951, 199 U.N.T.S. 67, art. 4.
Canada Labour Code, R.S.C., 1985, c. L-2, ss. 48, 80. Foreign Sovereign Immunities Act of 1976, Pub. L. 94-583, 90 Stat. 2891 (1976), s. 1603(d).
State Immunity Act, R.S.C., 1985, c. S-18, ss. 2, 3(1), 4 ( 1 ),( 2 )(a), 5.
State Immunity Act 1978 (U.K.), 1978, c. 33, s. 4(1), (6).
CASES JUDICIALLY CONSIDERED
APPLIED:
Goethe House New York, German Cultural Center v N.L.R.B., 869 F.2d 75 (2d Cir. 1989); revg 685 F.Supp. 427 (S.D.N.Y. 1988); The Charkieh (1873), L.R. 4 Ad. & Ec. 59.
CONSIDERED:
I Congreso del Partido, [1981] 2 All ER 1064 (H.L.); Texas Trading & Mill Corp. v. Federal Republic of Nigeria, 647 F.2d 300 (2d Cir., 1981).
REFERRED TO:
Gouvernement de la République Démocratique du Congo v. Venne, [1971] S.C.R. 997; 22 D.L.R. (3d) 669; Lorac Transport Ltd. v. Atra (The), [1987] 1 F.C. 108; (1986), 28 D.L.R. (4th) 309; 69 N.R. 183 (C.A.); Saint John, The Municipality of the City and County of et al. v. Fraser-Brace Overseas Corporation et al., [1958] S.C.R. 263.
AUTHORS CITED
Crawford, James "International Law and Foreign Sover eigns: Distinguishing Immune Transactions" The Brit- ish Yearbook of International Law 1983, Oxford: Cla- rendon Press, 1984.
Emanuelli, C. "L'immunité souveraine et la coutume internationale de l'immunité absolue à l'immunité rela tive" (1984), 22 Can. - Y.B. Int'l L. 26.
Molot, H.L. and Jewett, M.L. "The State Immunity Act of Canada" (1982), 20 Can.Y.B. Int'l L. 79.
United States. House Report No. 94-1487, Congressional Record, Vol. 122.
Williams, S.A. and de Mestral, A.L.C. An Introduction to International Law, 2nd ed. Toronto: Butterworths, 1987.
COUNSEL:
H. Scott Fairley for Canada Labour Rela tions Board.
Ronald A. Pink and Ronald Pizzo for Public Service Alliance of Canada.
Brian A. Crane, Q.C. for Government of the United States.
Edward R. Sojonky, Q.C. for Attorney Gen eral of Canada.
SOLICITORS:
Lang, Michener, Lash, Johnston, Toronto, for Canada Labour Relations Board.
Patterson, Kitz, Halifax, for Public Service Alliance of Canada.
Cowling, Strathy & Henderson, Ottawa, for Government of the United States.
Deputy Attorney General of Canada for Attorney General of Canada.
The following are the reasons for decision ren dered in English by
IACOBUCCI C.J.: I have had the benefit of read ing the reasons of my brother Mahoney J.A. and agree with those reasons and with the conclusion that he arrives at, namely, the United States of America ("United States") cannot claim state immunity under the State Immunity Act, R.S.C., 1985, c. S-18 (the "SIA") with respect to the application for certification filed by The Public Service Alliance of Canada (the "Union") under the Canada Labour Code, R.S.C., 1985, c. L-2 on behalf of certain Canadian civilians employed at the United States naval base at Argentia, New- foundland. However, I wish to add some comments of my own but in doing so will not refer to the general background that has been well described by Mr. Justice Mahoney.
With respect to the issue of whether or not the United States has waived immunity within the
meaning of the SIA, particularly paragraph 4(2)(a) thereof, I agree with Mahoney J.A. that the Board was correct in finding there had been no waiver. The Union argued that the United States' signing the 1951 North Atlantic Treaty Status of Forces Agreement [Agreement between the Parties to the North Atlantic Treaty regarding the status of their forces, June 19, 1951, 199 U.N.T.S. 67] amounted to an explicit submission to the jurisdic tion of Canadian courts. I cannot agree. At best, subscribing to the provisions of the Status of Forces Agreement may amount to an implicit waiver but paragraph 4(2)(a) of the SIA requires explicit submission to the jurisdiction of the court and I do not find anything in the provisions of the Status of Forces Agreement that constitutes explicit submission to judicial or adjudicative juris diction. Consequently, the Union's argument on waiver fails.
The more difficult issue by far in this reference centres on the question whether the matters over which the Board has exercised its jurisdiction "relate to any commercial activity of the foreign state" within the meaning of section 5 of the SIA which provides:
5. A foreign state is not immune from the jurisdiction of a court in any proceedings that relate to any commercial activity of the foreign state.
Section 2 of the SIA defines "commercial activity" to mean:
... any particular transaction, act or conduct or any regular course of conduct that by reason of its nature is of a commercial character;
The Board found that commercial activity was present and I agree, but, as I shall mention below, I have some doubt on the reasoning underlying the Board's conclusion on this issue.
I need not dwell at length on the doctrine of state or sovereign immunity under public interna tional law or whether Canadian courts favoured a restrictive approach to such immunity prior to the
enactment of the SIA.' Suffice it to say that under the traditional principle of sovereign immunity, each state ensured that no foreign state would be impleaded in its domestic legal processes except with the consent of the foreign state. The sovereign immunity was not immunity from the application of law of another state but rather immunity from process in its courts. The rationale was that to answer to an inquiry into any act of sovereignty would violate the principle of equality of states and threaten the dignity of the foreign state. 2 In effect, the dispute with the foreign state had to be dealt with by diplomatic means rather than by legal recourse.'
But eventually international practice on state immunity changed and national legislation was enacted to reflect this change of approach. 4 As noted by Mahoney J.A., the U.S. enacted its legis lation in 1976 followed by the United Kingdom in 1978 and by Canada in 1982. The change resulted in the abandonment of the so-called "absolute" theory of state immunity in favour of a "restric- tive" theory by which the immunity of the foreign state is limited to its sovereign or public acts (juri imperil) and does not extend to its private or commercial acts (juri gestionis).
A very helpful commentary on this relatively modern development of restrictive immunity has been given by Lord Wilberforce in I Congreso del Partido 5 when he said:
' See Gouvernement de la République Démocratique du Congo v. Venne, [1971] S.C.R. 997; 22 D.L.R. (3d) 669 especially Laskin J., as he then was, at p. 1020 S.C.R.; see also Lorac Transport Ltd. v. Atra (The), [ 1987] I F.C. 108; (1986), 28 D.L.R. (4th) 309; 69 N.R. 183 (C.A.).
2 See I Congreso del Partido, [1981] 2 All ER 1064 (H.L.); C. Emanuelli "L'immunité souveraine et la coutume Interna- tionale de l'immunité absolue à l'immunité relative" (1984), 22 Can. Y. B. Int'l L. 26.
3 See Saint John, The Municipality of the City and County of. et al. v. Fraser-Brace Overseas Corporation et al., [1958] S.C.R. 263, per Rand J., at p. 268.
4 See Williams, S.A. and de Mestral, A.L.C. An Introduction to International Law, 2nd ed. Toronto: Butterworths, 1987, pp. 139 et seq.
5 Supra, note 2.
The relevant exception, or limitation, which has been engrafted on the principle of immunity of states, under the so-called restrictive theory, arises from the willingness of states to enter into commercial, or other private law, transactions with individuals. It appears to have two main foundations. (a) It is necessary in the interest of justice to individuals having such transactions with states to allow them to bring such transac tions before the courts. (b) To require a state to answer a claim based on such transactions does not involve a challenge to or inquiry into any act of sovereignty or governmental act of that state. It is, in accepted phrases, neither a threat to the dignity of that state nor any interference with its sovereign functions. 6
I now return to the provisions of the SIA and, in particular, section 5 and the definition of commer cial activity in section 2. I wish to add two com ments to those made by Mahoney J.A. on the question of commercial activity. The first relates to the definition in section 2 of the SIA of com mercial activity and the second deals with a word of caution on the reasoning underlying the conclu sion reached by the Board with respect to commer cial activity.
In my view, the reference in the definition of commercial activity to any transaction, act or con duct that by reason of its nature is of a commercial character suggests a narrower scope for immunity than if the wording made reference to the purpose of the activity. Although the definition in the United States legislation expressly mentions the nature of the course of conduct or particular trans action or act, it goes on to state "rather than by reference to its purpose". But again as Mahoney J.A. points out, the Canadian definition implicitly conveys the same meaning, that is, one looks to the nature of the transactions or activity, not to its purpose. Looking to purpose as well would, in my view, tend to introduce a recognition of the wider net of immunity afforded under the traditional absolute theory, which could lead to defeating the statutory objective of adopting a restrictive
6 /d, at p. 1070; cited with approval by Hugessen J.A. in Lorac Transport Ltd., supra note I, at p. 115.
approach to immunity as reflected in the SIA. 7
Here the nature of the transaction or activity is commercial in that employment contracts entered into by the United States with Canadian civilians are at the heart of the matter and the certification proceedings before the Board relate to that com mercial activity within the meaning of section 5 of the SIA. Granted the purpose of the employment contracts is to further state or public objects of the United States operating a naval base, but, as mentioned, I believe the SIA and, in particular, the provisions of section 5 and the definition of commercial activity in section 2, do not counte nance the purpose or object of the state's activity but rather compel us to focus on the nature of the alleged commercial activity in issue.
One final comment relates to the reasoning of the Board in concluding there was commercial activity and that state immunity was not appli cable. The Board put considerable reliance on U.S. authorities, given, in their view, the close relation ship between the Canadian and U.S. legislation. The Board stated:
In the present case, the contract of employment of civilians engaged in maintenance duties gave rise to PSAC'S application for certification. Supposing that such a dispute had arisen in the United States, on a Canadian base, the question to be resolved would have been as follows: could such a contract have been entered into by a private party? In the affirmative, the contract would have been described as a commercial activity and the foreign base could not have claimed State immunity. Hiring civilian employees is an activity that can be performed by a private party, contrary to hiring "diplomatic, civil service, or military personnel" (Foreign Sovereign Immunities Act of 1976, House Report, supra, page 6615; emphasis added). It follows that, pursuant to the Foreign Sovereign Immunities Act of 1976, in circumstances such as found in this application for
7 See Molot, H.L. and Jewett, M.L. "The State Immunity Act of Canada", (1982) 20 Can. Y.B. Int'l L. 79; see particu larly the commentary at pp. 96 et seq. where the authors dicuss "Commercial Activity" and the emplasis on "nature" rather than "purpose" in the SIA. The authors point out that, as a matter of theory, it has been observed that a sovereign state does not cease to be a sovereign state because it performs an act which a private citizen might perform. Id, at p. 96. But the authors note that courts are now being asked to distinguish between the sovereign and non-sovereign, or the commercial and governmental, acts of a state and they go on to discuss why an emphasis on "nature" and not "purpose" is preferable. /d, at p. 99 et seq.
certification, hiring American civilian employees on a Canadi- an base located in the United States could be found to be a "commercial activity". 8
Although I agree with the Board's conclusion as to commercial activity, I would not put so great an emphasis on the question whether the contract of employment could have been entered into by a private party in every case that might arise under the SIA. To give an example, it may well be that the function of a computer programmer in a for eign state's military base could well be carried out by a private party, but if the work of the program mer were in relation to highly confidential and sensitive information gathering and analysis, I doubt whether such duties would constitute com mercial activity within the meaning of SIA so as to repel state immunity.
In summary, I agree with Mr. Justice Mahoney's answer to the question in this reference.
STONE J.A.: I agree.
* * *
The following are the reasons for decision ren dered in English by
MAHONEY J.A.: The issue in this reference is whether the Canada Labour Relations Board, hereinafter "the Board", erred in finding that the United States of America, hereinafter "the U.S.", could not claim state immunity as provided in section 3 of the State Immunity Act, R.S.C., 1985, c. S-18, with respect to an application for certifica tion filed on behalf of Canadian civilians employed by the U.S. Department of Defence at its base at Argentia, Newfoundland. Two other questions, dependent on a negative answer to that, relating to jurisdiction as between Canada and Newfound- land, while referred were not argued and will, if necessary, be subject of a later hearing.
The U.S. Navy, under a 99-year lease from Great Britain effective March 27, 1941, occupies
8 Case, at p. 34.
and operates a military base at Argentia. The lease provides:
ARTICLE I
(1) The United States shall have all the rights, power and authority within the Leased Areas which are necessary for the establishment, use, operation and defence thereof, or appropri ate for their control, and all the rights, power and authority within the limits of territorial waters and air spaces adjacent to, or in the vicinity of, the Leased Areas, which are necessary to provide access to and defence of the Leased Areas, or appropri ate for control thereof.
ARTICLE XXIX
The United States and the Government of the Territory respectively will do all in their power to assist each other in giving full effect to the provisions of this Agreement according to its tenor and will take all appropriate steps to that end.
During the continuance of any Lease, no laws of the Territo ry which would derogate from or prejudice any of the rights conferred on the United States by the Lease or by this Agree ment shall be applicable within the Leased Area, save with the concurrence of the United States.
In addition to its military and civilian personnel the U.S. employs about 60 Canadian civilians as firefighters and maintenance workers, such as plumbers, electricians, etc. The Public Service Alliance of Canada, hereinafter "the Union", has sought certification under the Canada Labour Code, R.S.C., 1985, c. L-2, as bargaining agent for those employees.
The base is contained within a patrolled perime ter fence. Access is through a guarded gate. It contains a communications centre, its raison d'être, housing and a variety of auxiliary service and supply buildings and facilities. The Canadian workers, other than the firefighters, are employed in the maintenance of the buildings, fence, grounds, utilities and equipment other than the communications equipment. Security clearance is required for their employment and admission to the base. Their admission to the communications centre itself, when necessary, is under military escort.
The relevant provisions of the State Immunity Act are:
2. In this Act,
"commercial activity" means any particular transaction, act or conduct or any regular course of conduct that by reason of its nature is of a commercial character;
3. (1) Except as provided by this Act, a foreign state is immune from the jurisdiction of any court in Canada.
4. (1) A foreign state is not immune from the jurisdiction of a court if the state waives the immunity conferred by subsec tion 3(1) by submitting to the jurisdiction of the court in accordance with subsection (2) or (4).
(2) In any proceedings before a court, a foreign state sub mits to the jurisdiction of the court where it
(a) explicitly submits to the jurisdiction of the court by written agreement or otherwise either before or after the proceedings commence;
5. A foreign state is not immune from the jurisdiction of a court in any proceedings that relate to any commercial activity of the foreign state.
It is agreed that the Board is a "court" for pur poses of this reference. The only issues are whether the U.S. has waived immunity and, if not, whether that over which the Board has asserted its jurisdic tion is a commercial activity.
The Board found that there had been no waiver and, before us, that conclusion was challenged only by the Union. The Board found that the activity was a commercial activity. Before us the U.S. and the Attorney General of Canada challenged, and the Union and Board defended, that finding.
WAIVER
The argument that the U.S. had waived immunity is founded on its subscription to the 1951 North Atlantic Treaty Status of Forces Agreement which provides in Article IX:
4. Local civilian labour requirements of a force or civilian component shall be satisfied in the same way as the comparable requirements of the receiving State and with the assistance of the authorities of the receiving State through the employment exchanges. The conditions of employment and work, in particu lar wages, supplementary payments and conditions for the protection of workers, shall be those laid down by the legisla tion of the receiving State. Such civilian workers employed by a force or civilian component shall not be regarded for any purpose as being members of that force or civilian component.
"Civilian component", by definition and in the circumstances, excludes the Canadian citizens and others ordinarily resident in Canada employed at the base.
The Board held that subscription to the NATO agreement did not constitute explicit submission to its jurisdiction no matter how liberally one might construe what could be a waiver. I agree.
COMMERCIAL ACTIVITY
At one time sovereign states enjoyed absolute immunity from the jurisdiction of common law courts. As they, directly or though their agencies, engaged increasingly in commercial activities, a "restrictive" concept of sovereign immunity came to be recognized. Canada, the U.S. and Great Britain, more or less contemporaneously, moved to codify that restrictive concept. The British statute, State Immunity Act 1978 (U.K.), 1978, c. 33, as it pertains to circumstances in issue here, is very different from the Canadian and American legisla tion. It excludes "a contract of employment be tween a State and an individual" from the defini tion "commercial transaction" but provides expressly:
4. (1) A State is not immune as respects proceedings relat ing to a contract of employment between the State and an individual where the contract was made in the United Kingdom or the work is to be wholly or partly performed there.
(6) In this section "proceedings relating to a contract of employment" includes proceedings between the parties to such a contract in respect of any statutory rights or duties to which they are entitled or subject as employer or employee.
The American statute, the Foreign Sovereign Immunities Act of 1976, Pub. L. 94-583, 90 Stat. 2891 (1976) as amended, provides:
1603. For purposes of this chapter
(d) A 'commercial activity' means either a regular course of commercial conduct or a particular commercial transaction or act. The commercial character of an activity shall be determined by reference to the nature of the course of conduct or particular transaction or act, rather than by reference to its purpose.
The ultimate clause, "rather than by reference to its purpose", in my view, conveys a notion not expressed but implicit in the Canadian definition.
In interpreting its statute, U.S. courts have rou tinely had recourse to the House Judiciary Com mittee's comments concerning the concept of com mercial activity it had in mind in commending the legislation to Congress. It is useful to quote it in its entirety.
(d) Commercial activity. Paragraph (c) of section 1603 defines the term `commercial activity" as including broad spectrum of endeavour, from an individual commercial transac tion or act to a regular course of commercial conduct. A "regular course of commercial conduct" includes the carrying on of a commercial enterprise such as a mineral extraction company, an airline or a state trading corporation. Certainly, if an activity is customarily carried on for profit, its commercial nature could readily be assumed. At the other end of the spectrum, a single contract, if of the same character as a contract which might be made by a private person, could constitute a "particular transaction or act".
As the definition indicates, the fact that goods or services to be procured through a contract are to be used for a public purpose is irrelevant; it is the essentially commercial nature of an activity or transaction that is critical. Thus, a contract by a foreign government to buy provisions or equipment for its armed forces or to construct a government building constitutes a commercial activity. The same would be true of a contract to make repairs on an embassy building. Such contracts should be considered to be commercial contracts, even if their ultimate object is to further a public function.
By contrast, a foreign state's mere participation in a foreign assistance program administered by the Agency for Interna tional Development (AID) is an activity whose essential nature is public or governmental, and it would not itself constitute a commercial activity. By the same token, a foreign state's activities in and "contracts" with the United States resulting from or necessitated by participation in such a program would not in themselves constitute a sufficient commercial nexus with the United States so as to give rise to jurisdiction (see sec. 1330) or to assets which could be subjected to attachment or execution with respect to unrelated commercial transactions (see sec. 1610(b)). However, a transaction to obtain goods or services from private parties would not lose its otherwise com mercial character because it was entered into in connection with an AID program. Also public or governmental and not commercial in nature, would be the employment of diplomatic, civil service, or military personnel, but not the employment of American citizens or third country nationals by the foreign state in the United States.
The courts would have a great deal of latitude in determining what is a "commercial activity" for purposes of this bill. It has seemed unwise to attempt an excessively precise definition of this term, even if that were practicable. Activities such as a foreign government's sale of a service or a product, its leasing of property, its borrowing of money, its employment or engage ment of labourers, clerical staff or public relations or marketing agents, or its investment in a security of an American corpora tion, would be among those included within the definition. House Report No. 94-1487, Congressional Record, Vol. 122, pp. 6614-6615. [My emphasis.]
The Congressional Record also discloses, at page 6604, that "the House bill was passed in lieu of the Senate Bill".
The British legislation by its terms and the American legislation by externally stated legisla tive intent exclude sovereign immunity in respect of the employment of their citizens or residents within their territories by foreign states. Decisions of U.S. courts have given effect to that legislative intent in considering individual employment con tracts. It is unnecessary to refer to any but the most recent American decision which, coinciden tally, is the most comparable, in a factual way, to the present case.
No decision of the U.S. Supreme Court has been cited to us but we were advised that certio- rari was being sought in respect of the very recent decision of the U.S. Court of Appeals for the Second Circuit in Goethe House New York, German Cultural Center y N.L.R.B., 869 F.2d 75 (2d Cir. 1989). Goethe House is a cultural agency of the Federal Republic of Germany which, inter alia, employs non-German personnel in the U.S. The proceeding in the U.S. courts was for an injunction to prevent the National Labour Rela tions Board from further processing a representa tion petition or conducting a representation elec tion for those employees. The District Court at trial, in a reported decision, 685 F.Supp. 427 (S.D.N.Y. 1988), granted the injunction, stating at page 429:
A denial of injunctive relief, resulting in Goethe House's having to go forward with the representation election, would undoubtedly cause Goethe House irreparable harm in the sensitive area of foreign relations, since Goethe House's employment policies are controlled entirely by the German government, and could engender diplomatic embarrassment if
the union prevailed in the election. Goethe House would then be forced either to bargain with the union in contravention of some or all of the German government's personnel mandates or, alternatively, to obtain review it would have to commit an unfair labour practice under the National Labor Relations Act, 29 U.S.C. § 158(a)(5), such as refusing to bargain with the union as the employees' representative.
and, at page 430:
It is however one thing to protect and preserve a remedy in American courts for an unpaid American vendor or employee by defining that relationship as a "commercial" exception, and on the other hand to justify thereby the right of a United States agency to intervene into the underlying employment structure of a conceded arm of a foreign state that is not involved in commercial activity. Support for this view is found in the fact that courts which have found the commercial activity exception to exist in the employment context have done so as to employ ment contracts between the foreign state or instrumentality and a single individual.
A majority of the Court of Appeals allowed the appeal on the ground that it was premature while also expressing by dicta doubt as to the probability of the Federal Republic's ultimate success in asserting state immunity [at pages 79 and 80].
To justify its assertion of jurisdiction, the district court wrote that requiring Goethe House to submit to NLRB jurisdiction might interfere with the West German government's "employ- ment objectives in implementing cultural foreign policy" and might cause disturbances and embarrassment in international relations. In our view, the district court's concerns were largely unfounded and did not warrant the court's intervention in the case. Even if the Union were certified as the bargaining agent of Goethe House's non-German employees, we fail to see how the presence of the Union would interfere with Goethe House's implementation of West German cultural foreign policy. Under the NLRA, Goethe House would have a duty to bargain with the Union over wages, hours and other terms and conditions of employment.... Moreover, the fact that the German employees at Goethe House presently are unionized belies the prospect that the presence of a union for the non-German employees would hamper Goethe House's operations.
As an employer, Goethe House has the option of seeking indirect review of the Board's order by refusing to bargain with the Union if it is certified, and then seeking review of its position in a court of appeals.
The dissenting member was in complete agreement with the trial judge. It is worth noting parentheti cally that it was precisely to avoid such an "indi- rect review" confrontation with the U.S. that the Board made the present reference.
The District Court had noted that all U.S. court decisions which invoked the commercial activity exception in the employment context had done so as to contracts of service between a foreign state and a single individual. The same is to be said of the authorities cited to us.
The Board's conclusion, after a thorough review of the American authorities, was:
Given the close relationship between the Canadian and Ameri- can legislations, we deem it appropriate to draw our inspiration from American authorities in order to define the concept of commercial activity. Specifically, we make ours the commercial activity test developed by American courts. If we apply this test to the present case, we find that the contract of employment of the Canadian civilian employees constitutes a commercial ac tivity within the meaning of section 2 of the State Immunity Act.
The American test adopted by the Board was concisely stated by the U.S. Court of Appeals for the Second Circuit in Texas Trading & Mill Corp. v. Federal Republic of Nigeria, 647 F.2d 300 (2d Cir., 1981), at page 309:
... put another way, if the activity is one in which a private person could engage, it is not entitled to immunity.
That case involved breach of contracts for the sale of cement and of related letters of credit.
I see no rational basis for distinguishing between contracts for the purchase of goods or services and contracts of employment for purposes of the State Immunity Act. If, as in my view he is, a supplier of electricity or groceries to the Argentia base is entitled to sue the U.S. for breach of contract in a Canadian court, there seems no reason why a Canadian civilian employee there should not have a like entitlement. However, as suggested by the Trial Judge in Goethe House, exercise by the Board of its jurisdiction to certify goes a good deal further than the enforcement of employees' rights
and employers' obligations under employment contracts.
Certification of a bargaining agent under the Canada Labour Code is not an end in itself. It gives the certified bargaining agent rights and, more important in the present circumstances, imposes obligations on the certified employer. Most immediately, if called upon to do so by the Union, the U.S. will be required to bargain with it for purposes of entering into a collective agree ment (section 48). Should that bargaining not result in a collective agreement, the Board may, subject to the intervention of the Minister of Labour, impose an initial agreement (section 80). I do not think it necessary to go beyond that thresh old in enumerating the obligations that the Code imposes on a certified employer and the coercive powers exercisable by the Board on motion of a certified bargaining agent.
While the common law has been supplanted by statute, the rationale for any measure of sovereign immunity at all remains as it was under the common law. It has been variously articulated, nowhere more succinctly than by Sir Robert Phil- limore in The Charkieh (1873), L.R. 4 Ad. & Ec. 59, at page 97.
The object of international law, in this as in other matters, is not to work injustice, not to prevent the enforcement of a just demand, but to substitute negotiations between governments, though they may be dilatory and the issue distant and uncer tain, for the ordinary use of courts of justice in cases where such use would lessen the dignity or embarrass the functions of the representatives of a foreign state;
The sovereign dignity of a foreign state seems clearly put in issue when a domestic tribunal can force it to bargain over the conditions of employ ment of its employees and, if permitted by a Minister of the Crown, impose those conditions. That is very different from a domestic tribunal enforcing the terms of a contract of employment the foreign state has freely entered into.
However, the narrow issue on this reference is whether, the certification proceeding before the Board "relates to any commercial activity" of the U.S. What is immediately in issue in a certifica tion proceeding is not the contracts of employment of the individuals in the proposed bargaining unit;
it is rather the right of the applicant union to bargain collectively for those employees and the obligation of the employer to likewise bargain. I have come to the conclusion that a certification proceeding does, nevertheless, "relate" to the employment of members of the proposed bargain ing unit under contracts of service, entry into which is, in my view, plainly "conduct ... of a commercial character" on the part of the U.S. I am unable to find anything peculiar to employ ment on the base that allows me to distinguish, in a meaningful way, the employment in issue. Only if one looks beyond the nature of the employment to its broad purpose—to serve the defence require ments of the U.S.—can invocation of state immunity be rationalized.
I am disturbed by this result. The difficulty I have experienced was anticipated by James Craw- ford, Professor of Law, University of Adelaide, in an article ["International Law and Foreign Sover eigns: Distinguishing Immune Transactions" pub lished in The British Year Book of International Law 1983, where he wrote, at page 92:
. although the forum State must be accorded some flexibility in the definition of `commercial transactions', these may be defined as contracts or related industrial or commercial activi ties, not being transactions governed by international law (such as treaties or public international arbitrations), and not being matters recognized as within the domestic jurisdiction of the foreign State. This latter consideration points to the desirability of distinguishing commercial transactions from contracts of employment: in some respects at least the relations between a State and its employees or servants are matters within its domestic jurisdiction. (The State Immunity Act 1982 (Can.) makes no specific provision for contracts of employment and thus asserts jurisdiction over all such contracts as would be regarded as `commercial transactions' on the basis, e.g., that there was a breach of contract within the jurisdiction. The difficulty is that in some respects (e.g. payment of wages due) such contracts may be `commercial transactions'; in other respects (e.g. placement or removal of public servants) they may impinge significantly on the internal administration of the defendant State.)
I conclude that if Parliament intended that foreign states be entitled to invoke immunity from the certification jurisdiction of the Board in respect of employment of Canadians in Canada, the State Immunity Act requires amendment.
CONCLUSION
I would answer the first question referred in the negative. The U.S. cannot claim state immunity with respect to the application for certification filed by the Union on behalf of Canadian civilians employed at its naval base at Argentia, Newfound- land.
STONE J.A.: I agree.
 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.