International Woodworkers of America, Local 2-69 v Consolidated-Bathurst Packaging Ltd, [1990] 1 SCR 282 is a leading Canadian administrative law case on the issue of procedural fairness and bias.

The International Woodworkers of America filed an application with the Ontario Labour Relations Board for relief, arguing that the management had not bargained in good faith as they did not disclose information relevant to the negotiations during the process.

[8] Gonthier J. summarized the court's opinion: The advantages of an institutionalized consultation process are obvious and I cannot agree with the proposition that this practice necessarily conflicts with the rules of natural justice.

The rules of natural justice must have the flexibility required to take into account the institutional pressures faced by modern administrative tribunals as well as the risks inherent in such a practice.

The safeguards attached to this consultation process are, in my opinion, sufficient to allay any fear of violations of the rules of natural justice provided as well that the parties be advised of any new evidence or grounds and given an opportunity to respond.

[9]The Supreme Court of Canada re-affirmed its decision in Tremblay v. Quebec (Commission des affaires sociales)[10] and Ellis-Don Ltd. v. Ontario (Labour Relations Board).