British Columbia v. Imperial Tobacco Canada

Tobacco companies challenged the constitutionality of the Tobacco Damages and Health Care Costs Recovery Act, which creates a legal action for the federal government against tobacco manufacturers to recover the health care costs for individuals with tobacco-related illnesses. The Supreme Court of British Columbia dismissed the government's actions. The Supreme Court of Canada upheld the constitutionality of the Recovery Act, finding British Columbia to have the closest relationship to the cause of action. The Court found that independence of judiciary was not violated and that the Act did not violate companies' right to a fair trial.

British Columbia v. Imperial Tobacco Canada, et al., [2005] 2 S.C.R. 473, Supreme Court of Canada (2005).

  • Canada
  • Sep 29, 2005
  • Supreme Court of Canada

Parties

Plaintiff

  • British American Tobacco (Investments) Limited
  • Imperial Tobacco Canada Limited
  • JTI‑Macdonald Corp.
  • Philip Morris Incorporated, Philip Morris International Inc.
  • Rothmans, Benson & Hedges Inc.

Defendant

  • Attorney General of British Columbia
  • Her Majesty the Queen in Right of British Columbia

Third Party

  • Attorney General for Saskatchewan
  • Attorney General of Alberta
  • Attorney General of Manitoba
  • Attorney General of New Brunswick
  • Attorney General of Newfoundland and Labrador
  • Attorney General of Nova Scotia
  • Attorney General of Ontario
  • Attorney General of Quebec

Legislation Cited

Tobacco Damages and Health Care Costs Recovery Act, S.B.C. 2000, c. 30.

Tobacco Damages Recovery Act, S.B.C. 1997, c. 41.

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"The Act does not implicate the rule of law in the sense that the Constitution comprehends that term. Except in respect of criminal law, the retrospectivity and retroactivity of which is limited by s. 11(g) of the Canadian Charter of Rights and Freedoms, there is no requirement of legislative prospectivity embodied in the rule of law or in any provision of our Constitution. Nor does the Constitution, through the rule of law, require that legislation be general in character and devoid of special advantages for the government (except where necessary for effective governance), or that it ensure a fair civil trial. In any event, tobacco manufacturers sued pursuant to the Act will receive a fair civil trial: they are entitled to a public hearing, before an independent and impartial court, in which they may contest the claims of the plaintiff and adduce evidence in their defence. The court will determine their liability only following that hearing, based solely on its understanding of the law as applied to its findings of fact. That defendants might regard the Act as unjust, or the procedural rules it prescribes as unprecedented, does not render their trial unfair."
"The Act does not violate the independence of the judiciary. A court called upon to try an action brought pursuant to the Act retains at all times its adjudicative role, and the ability to exercise that role without interference. It must independently determine the applicability of the Act to the government’s claim, independently assess the evidence led to support and defend that claim, independently assign that evidence weight, then independently determine whether its assessment of the evidence supports a finding of liability. The fact that the Act shifts onuses of proof in respect of some of the elements of an aggregate claim or limits the compellability of certain information does not in any way interfere, in either appearance or fact, with the court’s adjudicative role or any of the essential conditions of judicial independence. Judicial independence can abide unconventional rules of civil procedure and evidence.[55-56]"