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A-718-80
Evie Arghiri (Applicant) v.
J. L. Manion, Chairman of the Canadian Employ ment and Immigration Commission, and the Deputy Attorney General of Canada (Respond- ents)
Court of Appeal, Thurlow C.J., Urie J. and Kerr D.J.—Ottawa, January 19 and February 5, 1981.
Practice — Motion to strike pleadings — Application to quash application for judicial review — Applicant was sum marily dismissed from her position at the Canadian Embassy
in Athens Whether applicant's position was held during
pleasure only Whether respondent had a duty to act in a
judicial or quasi-judicial manner Motion is dismissed Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28 Interpretation Act, R.S.C. 1970, c. 1-23, ss. 22(1), 23(1).
The respondent applies to quash the application for judicial review for lack of jurisdiction. The applicant applied for judi cial review of her summary dismissal from her position at the Canadian Embassy in Athens on the grounds that the respond ent failed to observe the principles of natural justice, and that he was without jurisdiction to dismiss her and refuse her a pension. The Court record was not filed. The first question is whether the applicant's position was held during pleasure, and accordingly the applicant could be dismissed without a hearing. The second question is whether the respondent had a duty to exercise his authority to dismiss the applicant in a judicial or quasi-judicial manner, the answer to which depends upon whether the questions formulated in Minister of National Revenue v. Coopers and Lybrand [1979] 1 S.C.R. 495 have been positively answered. Those questions are: (1) Is there anything in the language in which the function is conferred or in the general context in which it is exercised which suggests that a hearing is contemplated before a decision is reached? (2) Does the decision affect the rights and obligations of persons? (3) Is the adversary process involved? (4) Is there an obligation to apply substantive rules to many individual cases rather than the obligation to implement social and economic policy in a broad sense?
Held, the motion is dismissed.
Per Thurlow C.J.: With respect to the first question, there is not sufficient information in the material before the Court to determine the nature of the position held by the applicant and it is not clear that that position was one to which the respond ent had appointed her or had authority to appoint her. With respect to the second question, this situation is a classic one for the implication that the decision to dismiss must be made on a judicial or quasi-judicial basis. The only ground for dismissal is misconduct. Accordingly., a quasi-judicial basis is indicated only because "misconduct" is not defined and no standards have been prescribed and that may admit of some flexibility and the application of policy considerations in the determina-
tion. With respect to the first criterion enunciated by the Supreme Court of Canada, the existence of a power to dismiss for misconduct, and particularly one found in a general context where a power to suspend for misconduct and for negligence in the performance of duties is subject to procedural and judicial safeguards, suggests that the exercise of the greater power to dismiss for misconduct is also to be subject to judicial safe guards. As to (2), the decision to dismiss for misconduct directly and seriously affects the employee both in the loss of employment and in consequential effects on rights incidental to his employment. As to (3), whenever the assertion of miscon duct is not admitted, there is an adversary process and a lis. With respect to (4), this is not a case of power to formulate or implement social or economic policy in a broad sense. It is a case of applying the concept to an individual case for the purpose of determining its existence or not. All four criteria point to the power of dismissal being one that is required by law to be exercised on a judicial or quasi-judicial basis.
Per Urie J.: The motion is dismissed on the ground that the material before the Court is insufficient.
Minister of National Revenue v. Coopers and Lybrand [1979] 1 S.C.R. 495, applied. Nicholson v. Haldimand- Norfolk Regional Board of Commissioners of Police [1979] 1 S.C.R. 311, referred to. Ridge v. Baldwin [1964] A.C. 40, referred to. Cooper v. Wandsworth Board of Works (1863) 14 C.B.N.S. 180, referred to. Martineau v. Matsqui Institution Disciplinary Board [1980] 1 S.C.R. 602, referred to.
APPLICATION. COUNSEL:
J. Bruce Carr-Harris for applicant. W. L. Nisbet, Q.C. for respondents.
SOLICITORS:
Scott & Aylen, Ottawa, for applicant.
Deputy Attorney General of Canada for respondents.
The following are the reasons for judgment rendered in English by
THURLOW C.J.: This is an application by the respondent for an order quashing on the ground that the Court does not have jurisdiction to enter tain it an application brought by the applicant, Evie Arghiri, under section 28 of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, to review and set aside a decision made by the respondent on or about June 1, 1978, "wherein the
applicant was dismissed from her position with the Canadian Embassy at Athens by virtue of section 6.48 of the Regulations for Locally-Engaged Staffs Abroad (1956) and wherein it was decided that she would not receive a pension by virtue of section 14(1)(g) of the Regulations Relating to Pensions for Locally-Engaged Employees pub lished by the Treasury Board."
The originating notice of application alleges as grounds:
(1) That the Respondent, Mr. Manion, failed to observe the principles of natural justice in refusing the Applicant an oppor tunity to hear the allegations made against her and to make some defence prior to dismissing the Applicant and denying her a pension;
(2) That the Respondent, Mr. Manion, was without jurisdic tion to dismiss the Applicant and refuse her a pension after 24 years of satisfactory service.
The objection to the jurisdiction of the Court raised by the respondent is that the decision so attacked was an administrative decision that was not required by law to be made on a judicial or quasi-judicial basis and accordingly was not a decision of the kind which the Court has jurisdic tion to review under section 28 of the Federal Court Act'.
On a motion to quash at this stage it is, I apprehend, incumbent on the party bringing the motion to put before the Court in an acceptable form the facts which show that the proceeding is not one of the kind the Court can properly enter tain. In the present instance, the record required by Rule 1402(3) to be forwarded to the Court for the purpose of determining the section 28 applica tion has not been filed and the material on which the motion must be decided is scanty. It appears to me to afford an incomplete and unsatisfactory basis for determining the validity of points raised by the respondent on which the jurisdiction of the Court depends.
' 28. (1) Notwithstanding section 18 or the provisions of any other Act, the Court of Appeal has jurisdiction to hear and determine an application to review and set aside a decision or order, other than a decision or order of an administrative nature not required by law to be made on a judicial or quasi-judicial basis, made by or in the course of proceedings before a federal board, commission or other tribunal ...
The material consists of (1) several paragraphs contained in a memorandum of argument on the motion filed on behalf of the applicant, which were, for the purposes of this motion, adopted at the hearing by counsel for the respondent, and (2) an affidavit of Bernard Brodie, filed on behalf of the respondent in support of the motion to quash.
The paragraphs from the applicant's memoran dum are as follows:
(a) The Applicant is a Greek citizen and was hired as an office secretary at the Canadian Embassy in Athens in February of 1954.
(b) More than 24 years later, the Applicant having been promoted to the level of Immigration Program Officer and having a work record described as "fully satisfactory", she was summarily dismissed on grounds of alleged misconduct relating to the "misuse of her position".
(c) The decision to dismiss the Applicant included extin- guishment of her pension rights based upon her 24 years of employment.
(d) Both before and after the effective date of her dismissal, being July 7th, 1978, the Applicant consistently requested specification of the allegations against her and an opportu nity to respond thereto but her requests were consistently refused.
(e) As a result of her dismissal the Applicant is only able to obtain casual employment in Greece as she is without a Work Certificate relating to her position of over 24 years with the Canadian Embassy. In addition the Applicant is considered by her National Insurance Fund Organization to have been a permanent member of the Canadian government service and as such has no right to receive a pension from the Greek authorities.
3. At the time of the Applicant's dismissal, the Applicant's employment was governed by the Regulations Governing Employment of Staffs Engaged Locally Outside Canada (1956).
The Brodie affidavit reads as follows:
I, BERNARD BRODIE, of the City of Ottawa, in the Province of Ontario, Public Servant, make oath and say as follows:
1. That in or about the month of October 1977 I assumed duties as the Special Projects Officer, Foreign Branch, Employ ment and Immigration Commission, Ottawa, and on or about June 28, 1978 I assumed the duties and responsibilities of the Chief, Personnel Administration, Foreign Branch, Employment and Immigration Commission, Ottawa, and while performing the duties of those positions I had complete access to the personnel records of the Foreign Branch, Employment and Immigration Commission, including those pertaining to the Applicant, and the facts hereinafter deposed to are based on my examination of those records.
2. The Respondent J.L. Manion, was Chairman of the Employ ment and Immigration Commission at all times relevant to these proceedings and remained Chairman until August 31, 1979. The Applicant commenced employment as a member of the locally engaged staff employed at the Canadian Embassy, Athens, Greece, on February 4, 1954. Her employment at that Embassy continued until July 7, 1978, on which date her dismissal became effective. At the time of her dismissal the Applicant was employed as an Immigration Program Assistant.
3. The Applicant was employed pursuant to the Regulations governing employment of staffs engaged locally outside Canada approved by the Treasury Board on April 12, 1956 and made pursuant to paragraph 7(c) of the Financial Administration Act, R.S.C. 1952, c. 116. These Regulations are now produced and shown to me and marked Exhibit "A" to this my Affidavit. The Regulations marked Exhibit "A" to this my Affidavit were replaced by the Locally Engaged Staffs' Terms and Conditions Regulations approved by the Treasury Board on July 17, 1978 and made pursuant to paragraph 5(e) of the Financial Administration Act, R.S.C. 1970, c. F-10. Now produced and shown to me and marked Exhibit "B" to this my Affidavit is a copy of the Locally Engaged Staff Terms and Conditions Regulations.
4. The Respondent J.L. Manion, in the exercise of his authority as Chairman of the Employment and Immigration Commission (a position he held by virtue of his appointment as Deputy Minister of Employment and Immigration) decided on June 1, 1978 to discharge the Applicant. The Applicant was advised by letter dated June 20, 1978 that she would be discharged from her employment effective July 7, 1978. A copy of the letter of June 20, 1978 is now produced and shown to me and marked Exhibit "C" to this my Affidavit.
5. As a person employed pursuant to the Regulations governing employment of staffs engaged locally outside Canada (1956), the Applicant's terms and conditions of employment did not include the right to present a grievance concerning the interpre tation of application in respect of her of any term or condition of her employment or concerning any termination of her employment by her superiors. Nor do these Regulations express any tenure of employment for the Applicant other than during pleasure only.
6. By Section 5.2.2, the Locally Engaged Staffs' Terms and Conditions Regulations (1978), provision is made for the pres entation of grievances by persons to whom those Regulations apply concerning the termination of employment of such per sons initiated by the relevant Head of Post Abroad. The grievance procedure so provided does not include the right to refer any grievance for review to a third party and the reply of the Deputy Head at the final level of the procedure is final and conclusive as against the aggrieved employee for all purposes. See subparagraph 5.2.2(5) of the Regulations.
7. The Locally Engaged Staffs' Terms and Conditions Regula tions (1978) were not distributed to Canadian Posts abroad until approximately nine months after their approval by the Treasury Board on July 17, 1978.
8. The Applicant made no attempt to invoke the grievance procedure prescribed by Section 5.2.2 of the Locally Engaged Staffs' Terms and Conditions Regulations (1978) although she did complain in writing about the termination of her employment.
9. The Applicant's complaint was considered by the Respond ent J.L. Manion and others then under his managerial author ity and was rejected. In giving consideration to the Applicant's complaint the Respondent J.L. Manion was acting as a senior representative of one of the parties to the difference or dispute concerning the Applicant's termination of employment, i.e., the employer. He was not acting as a Judge or Adjudicator. In deciding to discharge the Applicant and to reject her complaint against her discharge the Respondent J.L. Manion was acting in a purely administrative capacity, and his decision was not required by law to be made on a judicial or quasi-judicial basis.
10. The Applicant while employed at the Canadian Embassy in Athens was a "Public Officer" within the meaning of that expression as defined in sub-section 2(1) of the Interpretation Act, R.S.C. 1970, c. I-23. As such a "Public Officer" she must be deemed to have been appointed to hold that office during pleasure only pursuant to sub-section 22(1) of the Interpreta tion Act, as no other tenure was expressed in her appointment.
11. During her period of employment at the Canadian Embassy at Athens, the Applicant was covered by a pension plan regu lated by the Locally Engaged Employees Pension Regulations, a copy of which is now produced and shown to me and marked Exhibit "D" to this my Affidavit.
12. During the period of her employment from 1954 to 1974 the Applicant was not required to make any contribution to the cost of that Plan. During the period of her employment from January 1, 1975 to July 7, 1978 the Applicant was required to pay a contribution in part payment of the cost of her Pension Plan. The remaining part was paid by the Government of Canada.
13. At the time of the Applicant's termination of employment on July 7, 1978, she was entitled only to a return of the amount of her contributions with interest. The sum of 62,839 drachmas (Greek) was paid to the Applicant on or about August 2, 1978 representing the amount of the contributions she had made to the cost of her Pension Plan since January 1, 1975, plus interest at the rate of 4% per annum. A copy of a letter dated July 31, 1978 sent to the Applicant advising her of the amount of her pension contribution being returned to her is now produced and shown to me and marked Exhibit "E" to this my Affidavit.
14. Under the Locally Engaged Employees Pension Regula tions, the Deputy Minister, by virtue of paragraph 7(2) thereof, has the unfettered discretion to grant, reduce, or withhold payment to an employee to whom those Regulations apply.
15. This Affidavit is sworn in support of an Application made by the Respondents pursuant to Rule 1100 of the General Rules and Orders of the Federal Court of Canada to quash these proceedings under paragraph 52(a) of the Federal Court Act.
It will be observed that this affidavit is more akin to a brief of argument than a statement of facts. It is replete with argumentation and conclu sions of mixed fact and law, including interpreta tions of the effect of documents, none of which is admissible or entitled to weight. As a whole, the affidavit adds little if anything at all to the facts
recited in the applicant's memorandum save that it exhibits copies of the Regulations and letters referred to therein. It is particularly deficient in not exhibiting the documents relating to the appli cant's engagement and promotion.
The first point put forward in support of the motion (though it was neither pressed nor aban doned) was that under subsection 22(1) 2 of the Interpretation Act, R.S.C. 1970, c. I-23, the appli cant's position was one held during pleasure and that under subsection 23 (1) of the same Act, the applicant could be dismissed without a hearing by the respondent who, it was said, was authorized to exercise the power of subsection 23 (1) 3 because he was the person who had the power to appoint the applicant to her position.
It does not appear to me that there is sufficient information in the material before the Court, at this stage, to determine the nature of the position held by the applicant, and it is not clear that that position was one to which the respondent had appointed her or had authority to appoint her. Accordingly, in so far as the motion may be founded on the submission that the respondent had an unbridled discretion under subsection 23(1) of the Interpretation Act to dismiss the applicant for misconduct without informing her of the charge of misconduct or affording her a hearing, I do not think the facts that would support such a submis sion have been established with sufficient clarity to enable the Court to pass upon it at this stage of the proceedings. I add, however, that even if in exer cising the power conferred by subsection 23(1)
2 22. (1) Every public officer appointed before, on or after the 1st day of September 1967, by or under the authority of an enactment or otherwise, shall be deemed to have been appoint ed to hold office during pleasure only, unless it is otherwise expressed in the enactment or in his commission or appointment.
3 23. (1) Words authorizing the appointment of a public officer to hold office during pleasure include the power of
(a) terminating his appointment or removing or suspending him,
(b) re-appointing or reinstating him, and
(c) appointing another in his stead or to act in his stead,
in the discretion of the authority in whom the power of appointment is vested.
there is no requirement that the person concerned be given a hearing, a point which is similar to one discussed in the judgment of the majority of the Supreme Court in Nicholson v. Haldimand-Nor- folk Regional Board of Commissioners of Police [1979] 1 S.C.R. 311 at page 322, the power does not appear to me to be more than a power to revoke the appointment and remove the incumbent from the position by terminating the pleasure at which the appointment is held. The subsection does not include the word "dismiss" 4 or the ex pression "dismiss for misconduct". As I read it, while the subsection authorizes removal from office, it does not authorize a dismissal for miscon duct with the consequences which such a dismissal entails in addition to the loss of the office itself.
Accordingly, I do not think the present motion can succeed on the ground so put forward, at least on the material presently before the Court.
The second point put forward, as I understood it, was that as the deputy head of the Department of Employment and Immigration, the respondent had authority under the Regulations for locally- engaged staffs abroad to dismiss the applicant, that his power to do so was purely administrative and that even if in exercising it fairly 5 he would have been required to afford the applicant a hear ing, the power was not one that was required by law to be exercised on a judicial or quasi-judicial basis. It would follow that review under section 28 of the Federal Court Act would not be open though certiorari under section 18 might be.
The Regulations referred to are said to have been made in 1956 under paragraph 7(c) of the Financial Administration Act, R.S.C. 1952, c. 116, that is to say, some two years after the applicant was first employed. Whether the provi sions of these Regulations which authorize employment and termination of employment by the persons therein mentioned had the force of law is not clear having regard to the provisions of the Civil Service Act then in force. However, both
4 Compare the wording used in the Civil Service Act, R.S.C. 1952, c. 48, s. 52.
5 Compare Nicholson v. Haldimand-Norfolk Regional Board of Commissioners of Police [1979] 1 S.C.R. 311 and Martineau v. Matsqui Institution Disciplinary Board [1980] 1 S.C.R. 602.
parties treated them as governing the applicant's employment. Assuming, as the parties have done, that the applicant's employment was governed by the Regulations it seems to me that any power the deputy head may have had to dismiss the applicant from the Public Service was that provided by the Regulations and that this would be the extent of his power to dismiss her even if, apart from such Regulations, the applicant's position or office would have fallen within the first class of employ ment described by Lord Reid in Ridge v. Baldwin [ 1964] A.C. 40 at page 65. 6
The Regulations provide in section 6.10 that, subject to certain specified conditions, appoint ments may be made by the deputy head of the department concerned. They say nothing about the tenure of such appointments. Part VII deals with suspension. It provides:
6.27 CONDITIONS TO BE MET IN CASES OF SUSPENSION
(1) The Head of Post may suspend from the performance of his duties for such period as he deems warranted, any employee guilty of misconduct or negligence in the performance of his duties, and shall report all such suspen sions to the deputy head.
(2) An employee placed under suspension by the Head of Post has the right of appeal to the deputy head.
(3) No salary shall be paid to an employee for any period during which he is under suspension, unless the deputy head is of opinion that the suspension was unjust or made in error or that the punishment inflicted was too severe.
It will be observed that provision is made for an appeal to the deputy head by an employee who has been suspended by the Head of Post because of misconduct or negligence in the performance of
6 The law regarding master and servant is not in doubt. There cannot be specific performance of a contract of service, and the master can terminate the contract with his servant at any time and for any reason or for none. But if he does so in a manner not warranted by the contract he must pay damages for breach of contract. So the question in a pure case of master and servant does not at all depend on whether the master has heard the servant in his own defence: it depends on whether the facts emerging at the trial prove breach of contract. But this kind of case can resemble dismissal from an office where the body employing the man is under some statutory or other restriction as to the kind of contract which it can make with its servants, or the grounds on which it can dismiss them. The present case does not fall within this class because a chief constable is not the servant of the watch committee or indeed of anyone else.
duties and that under subparagraph (3) an opinion is to be formed by the deputy head as to whether the suspension was just or made in error or the punishment was too severe. That, to my mind, suggests that on an appeal by the employee under the provision a judicial, or perhaps a quasi-judi cial, function is to be exercised by the deputy head.
Part IX is concerned with separations. It con sists of a number of paragraphs, entitled respec tively, "Resignation", "Release or Dismissal", "Abandonment of Position" and "Retirement on Account of Age". The paragraph entitled "Release or Dismissal" reads:
6.48 RELEASE OR DISMISSAL
(1) The deputy head may terminate the employment of an employee or a maintenance employee by reason of reduc tion in strength, unsuitability, unsatisfactory service or inefficiency, or dismiss him on account of misconduct.
(2) Any person who is dismissed for misconduct shall not be paid any remuneration in respect of any period after the day he ceased duty, except to the extent required by the law of the country in which the post is situated.
It will be seen that this provision distinguishes, both in its title and in its wording, between release or termination and dismissal and that while there are several grounds for release or termination the only ground for dismissal is misconduct. Moreover, the prohibition of subparagraph (2) applies only in the case of dismissal for misconduct. There is no provision for an appeal to the deputy head, as there is in the case of a suspension, the authority to dismiss being that of the deputy head himself. Nor is there any definition of what constitutes misconduct.
In my view, notwithstanding the lack of any provision in the paragraph for procedure to dis miss, this situation is a classic one for the implica tion that the decision to dismiss must be made on a judicial or a quasi-judicial basis. I say quasi-judi cial only because "misconduct" is not defined and no standards have been prescribed and that may conceivably admit of some flexibility and the application of policy considerations in the determi nation. But in either case, the power to dismiss arises only when there has been misconduct and, as I see it, the determination of misconduct can be made only on a judicial or possibly, for the reason I have indicated, a quasi-judicial basis after
exploring the facts considered to amount to mis conduct and hearing both sides on the issue. The kind of hearing and the procedure to be followed in conducting it are not matters which for present purposes need be discussed.
The principle is an old one and, as it seems to me, is nowhere better expressed than in the judg ment of Byles J. in Cooper v. Wandsworth Board of Works (1863) 14 C.B.N.S. 180. In that case, the Board had authority in specified circumstances to demolish a privately owned building and did so without affording the owner a hearing. The statute did not expressly provide for a hearing by the Board before exercising the power. Byles J. said at pages 194-195:
It seems to me that the board are wrong whether they acted judicially or ministerially. I conceive they acted judicially, because they had to determine the offence, and they had to apportion the punishment as well as the remedy. That being so, a long course of decisions, beginning with Dr. Bentley's case (Rex v. The Chancellor, &c. of Cambridge, 1 Stra. 557; 2 Ld. Ray. 1334; 8 Mod. 148; Fortescue, 202), and ending with some very recent cases, establish, that, although there are no positive words in a statute requiring that the party shall be heard, yet the justice of the common law will supply the omission of the Legislature. The judgment of Mr. Justice FORTESCUE, in Dr. Bentley's case, is somewhat quaint, but it is very applicable, and has been the law from that time to the present. He says, "The objection for want of notice can never be got over. The laws of God and man both give the party an opportunity to make his defence, if he has any. I remember to have heard it observed by a very learned man, upon such an occasion, that even God himself did not pass sentence upon Adam before he was called upon to make his defence. `Adam' (says God), `where art thou? Hast thou not eaten of the tree whereof I commanded thee that thou shouldest not eat?' And the same question was put to Eve also." If, therefore, the board acted judicially, although there are no words in the statute to that effect, it is plain they acted wrongly.
In M.N.R. v. Coopers and Lybrand' Dickson J. formulated four criteria for determining whether a decision or order is one required by law to be made on a judicial or quasi-judicial basis as follows:
(1) Is there anything in the language in which the function is conferred or in the general context in which it is exercised which suggests that a hearing is contemplated before a decision is reached?
7 [1979] 1 S.C.R. 495 at page 504.
(2) Does the decision or order directly or indirectly affect the rights and obligations of persons?
(3) Is the adversary process involved?
(4) Is there an obligation to apply substantive rules to many individual cases rather than, for example, the obligation to implement social and economic policy in a broad sense?
The list was not intended to be exhaustive. Adverting to the four criteria in turn, with respect to the first it seems to me that the existence of a power to dismiss for misconduct, and particularly one found in a general context where a power to suspend for misconduct and for negligence in the performance of duties is subject to procedural and judicial safeguards, suggests that the exercise of the greater power to dismiss for misconduct is also to be subject to judicial safeguards. As to (2), it is obvious that the decision to dismiss for misconduct directly and seriously affects the employee both in the loss of employment and in consequential effects on rights incidental to his employment as well as in his prospects for future employment. As to (3), it seems to me, that the determination of misconduct, which is a prerequisite of the exercise of the power to dismiss, must in the nature of things result from an assertion by someone of misconduct on the part of the employee which gives rise to an issue between that person or some other person who takes up and pursues or reports the assertion to the proper authority on the one hand and the employee on the other. In that sense, whenever the assertion of misconduct is not admit ted, there is an adversary process and a lis. With respect to (4), this is not a case at all of a power to formulate or implement social or economic policy in a broad sense. But within the limits of an undefined but not hard to understand concept of misconduct, it is a case of applying the concept to an individual case for the purpose of determining its existence or not. All four criteria in my opinion point to the power of dismissal in question being one that is required by law to be exercised on a judicial or quasi-judicial basis.
Accordingly, I would dismiss the motion.
The following are the reasons for judgment rendered in English by
URIE J.: I agree with the Chief Justice that the motion to quash the within section 28 application should be dismissed. I would prefer not to express an opinion at this stage on the issue as to whether or not the decision to dismiss the applicant for misconduct is one which is required by law to be made on a judicial or quasi-judicial basis. I think that determination can, perhaps, best be decided when there is more factual material before the Court. I am content, therefore, to base my agree ment on the disposition of the motion simply on the ground that the material presently before the Court is insufficient to permit the motion to succeed.
* * *
KERR D.J.: I agree.
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