What is the scope of an administrative tribunal’s discretion to adjourn proceedings?

Ontario, Canada


The following excerpt is from Spence v. Ontario College of Teachers, 2018 ONSC 3335 (CanLII):

As described in Prassad v. Canada (Minister of Employment and Immigration), 1989 CanLII 131 (SCC), [1989] 1 S.C.R. 560 at pp. 568-69, a tribunal’s discretion is broad: We are dealing here with the powers of an administrative tribunal in relation to its procedures. As a general rule, these tribunals are considered to be masters in their own house. In the absence of specific rules laid down by statute or regulation, they control their own procedures subject to the proviso that they comply with the rules of fairness and, where they exercise judicial or quasi-judicial functions, the rules of natural justice. Adjournment of their proceedings is very much in their discretion.

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