National Corn Growers Assn v Canada (Import Tribunal)

The Tribunal found that the subsidization of grain imports were potentially the cause of "material injury" to the production in Canada.

Justice Gonthier, applying the analysis in Canadian Union of Public Employees, Local 963 v. New Brunswick Liquor Corp. 1979 found that the standard under which the decision can be reviewed is one of patent unreasonableness.

Justice Wilson, in concurrence, considered meaning of the advent of the "pragmatic and functional approach" found in the NB Liquor case and in U.E.S., Local 298 v. Bibeault, 1988.

In contrast to Gonthier, who assessed whether the Tribunal had made a patently unreasonable error with respect to each issue before the Court, Wilson wrote that a proper application of the approach required a more general assessment of the Tribunal's decision.

The court's job, she noted, was to determine whether the Tribunal had made a patently unreasonable error in the sense that it exceeded the statutory mandate given to it by Parliament.