Manitoba Métis Federation v Canada (Attorney General)
Court: Supreme Court of Canada
Citation: 2013 SCC 14
TAGS: Honour of the Crown; Fiduciary Duty
The honour of the Crown includes a duty of diligence in fulfilling obligations.
In 1870, Manitoba was created by the Manitoba Act through negotiations between Métis and Canadian leadership. The Act provided that 1.4 million acres of land would be given to Métis children, and that existing landholdings would be recognized. Through a series of errors and delays, the allocation of the land resulted in less land than was promised being given at a delay, often to spectators, and sometimes not at all. The Manitoba Métis Federation (MMF), on behalf of the Métis people in Manitoba, sought for the court to declare that the federal government breached its fiduciary duty, was not consistent with the honour of the Crown in allotting the land that was promised. The MMF also sought for a declaration that Manitoba legislation that affected the implementation of the Manitoba Act was not under provincial jurisdiction.
At trial, the claim was dismissed because the Métis held land individually, limitations barred the claim, and the court stated that while individual claimants might have standing, the MMF did not. At the Manitoba Court of Appeal, the claim was also dismissed. The court found that there was not a breach of fiduciary duty, that there was no claim in regard to the honour of the Crown, and that that MMF did not have standing. The MMF appealed to the Supreme Court of Canada (SCC), where the appeal was granted. The SCC found that the MMF had standing to bring the claim. Though the SCC found that there was no fiduciary duty in allocating the lands, it found that the federal government had not implemented the Manitoba Act in a manner that was consistent with the honour of the Crown.
Why this Case Matters:
This case establishes that, where the honour of the Crown is engaged, the federal government must act diligently and effectively in fulfilling its obligations. The federal government must implement its agreements to the best of its ability. Fulfilling obligations in an “ineffectual and inequitable manner” does not meet this requirement.
Supreme Court Judgment: