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35916

Sundance Saloon Limited, et al. v. Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance, et al.

(Newfoundland & Labrador) (Civil) (By Leave)

Docket

Judgments on applications for leave to appeal are rendered by the Court, but are not necessarily unanimous.

List of proceedings
Date Proceeding Filed By
(if applicable)
2014-10-27 Close file on Leave
2014-10-24 Copy of formal judgment sent to Registrar of the Court of Appeal and all parties
2014-10-24 Judgment on leave sent to the parties
2014-10-23 Judgment of the Court on the application for leave to appeal, The application for leave to appeal and the applications for leave to cross-appeal from the judgment of the Supreme Court of Newfoundland and Labrador - Court of Appeal, Number 12/27, 2014 NLCA 15, dated March 31, 2014 are dismissed with costs.
Dismissed, with costs
2014-10-23 Judgment of the Court on the application for leave to cross-appeal
Dismissed, with costs
2014-09-22 All materials on application for leave submitted to the Judges, Abe Ro Mo
2014-09-22 All material on the application for leave to cross-appeal submitted to the Judges, Abe Ro Mo
2014-08-26 Memorandum of argument in response to the cross-appeal, (Letter Form), Completed on: 2014-08-26, (Electronic version filed on 2014-08-26) Sundance Saloon Limited
2014-06-27 Certificate (on limitations to public access) Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance
2014-06-27 Application for leave to cross-appeal, (Included in the respondent's response on the application for leave to appeal), Completed on: 2014-06-27 Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance
2014-06-27 Respondent's response on the application for leave to appeal, Completed on: 2014-06-27 Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance
2014-06-27 Certificate (on limitations to public access) Newfoundland and Labrador Liquor Corporation
2014-06-27 Notice of name Newfoundland and Labrador Liquor Corporation
2014-06-27 Application for leave to cross-appeal, (Included in the respondent's response on the application for leave to appeal), Completed on: 2014-06-27 Newfoundland and Labrador Liquor Corporation
2014-06-27 Respondent's response on the application for leave to appeal, Completed on: 2014-06-27 Newfoundland and Labrador Liquor Corporation
2014-05-29 Letter acknowledging receipt of a complete application for leave to appeal, File opened on 2014-05-29
2014-05-29 Certificate (on limitations to public access) Sundance Saloon Limited
2014-05-29 Notice of name Big Ben's Limited
2014-05-29 Notice of name Sundance Saloon Limited
2014-05-29 Application for leave to appeal, Completed on: 2014-05-29 Sundance Saloon Limited

Parties

Please note that in the case of closed files, the “Status” column reflects the status of the parties at the time of the proceedings. For more information about the proceedings and about the dates when the file was open, please consult the docket of the case in question.

Main parties

Main parties - Appellants
Name Role Status
Sundance Saloon Limited Applicant Active
Big Ben's Limited Applicant Active

v.

Main parties - Respondents
Name Role Status
Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance Respondent Active
Newfoundland and Labrador Liquor Corporation Respondent Active

Counsel

Party: Sundance Saloon Limited

Counsel
Name
David P. Goodland
Contact information
Goodland O'Flaherty
16 Forest Road
Suite 200
St. John's, Newfoundland & Labrador
A1C 2B9
Telephone: (709) 722-4700
FAX: (709) 722-4720
Email: david@goodlandoflaherty.com
Agent
Name
Patricia J. Wilson
Contact information
Osler, Hoskin & Harcourt LLP
340 Albert Street
Suite 1900
Ottawa, Ontario
K1R 7Y6
Telephone: (613) 787-1009
FAX: (613) 235-2867
Email: pwilson@osler.com

Party: Big Ben's Limited

Counsel
Name
David P. Goodland
Contact information
Goodland O'Flaherty
16 Forest Road
Suite 200
St. John's, Newfoundland & Labrador
A1C 2B9
Telephone: (709) 722-4700
FAX: (709) 722-4720
Email: david@goodlandoflaherty.com
Agent
Name
Patricia J. Wilson
Contact information
Osler, Hoskin & Harcourt LLP
340 Albert Street
Suite 1900
Ottawa, Ontario
K1R 7Y6
Telephone: (613) 787-1009
FAX: (613) 235-2867
Email: pwilson@osler.com

Party: Her Majesty the Queen in Right of Newfoundland and Labrador, as Represented by the Minister of Finance

Counsel
Name
Rolf Pritchard, Q.C.
Contact information
Attorney General of Newfoundland and Labrador
4th Floor, East Block Confederation Bldg.
P.O. Box 8700, Stn. A
St. John's, Newfoundland & Labrador
A1B 4J6
Telephone: (709) 729-5942
FAX: (709) 729-2129
Email: rolfpritchard@gov.nl.ca
Agent
Name
Robert E. Houston, Q.C.
Contact information
Burke-Robertson
441 MacLaren Street
Suite 200
Ottawa, Ontario
K2P 2H3
Telephone: (613) 236-9665
FAX: (613) 235-4430
Email: rhouston@burkerobertson.com

Party: Newfoundland and Labrador Liquor Corporation

Counsel
Name
Daniel W. Simmons, Q.C.
Contact information
McInnes Cooper
10 Fort William Place
5th Floor, Baine Johnston Centre
St. John's, Newfoundland & Labrador
A1C 5X4
Telephone: (709) 722-8735
FAX: (709) 722-1763
Email: daniel.simmons@mcinnescooper.com

Summary

Keywords

None.

Summary

Case summaries are prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch). Please note that summaries are not provided to the Judges of the Court. They are placed on the Court file and website for information purposes only.


Constitutional Law – Taxation – Scope and application of a province’s taxing powers – Distinction between indirect and direct taxation – Whether Legislature may retain monies taken from one group of taxpayers pursuant to an unconstitutional indirect tax as satisfaction for a retroactive direct tax levied on a different group of taxpayers – Whether a Legislature may justify the confiscation of an ultra vires tax on one taxpayer by passing legislation against a different taxpayer in an attempt to give effect to an ultra vires tax – Whether allowing “passing on” as a defence barring restitution of monies collected pursuant to an unconstitutional tax conflicts with Kingstreet Investments Ltd. v. New Brunswick (Department of Finance), 2007 SCC 1, [2007] 1 S.C.R. 3.

The applicants are lounges in the Province of Newfoundland and Labrador, licensed to purchase wines and spirits from the Newfoundland and Labrador Liquor Corporation for re-sale to customers. They paid a 10% levy to the Province on all of their purchases of wines and spirits between 2001 and 2006. On February 16, 2007, the class filed a Statement of Claim seeking a declaration that the levy was ultra vires the Province and seeking restitution of the monies paid under the levy. In 2008, in An Act to Amend the Liquor Control Act, S.N.L. 2008 c. 14, the Legislature amended the Liquor Control Act, R.S.N.L. 1990, c. L-18, and introduced, in s. 56.1, a retroactive tax on purchases of spirits and wines by the class members’ customers during the same time period as the levy. The amendments require the class to collect and remit the tax to the Province. The tax is calculated on retail sales prices but the Legislature deemed the amounts paid by the class pursuant to the levy to be payment in full for the tax.

Lower court rulings

January 30, 2012
Supreme Court of Newfoundland & Labrador, Trial Division

200701T0748

Action dismissed

March 31, 2014
Supreme Court of Newfoundland and Labrador - Court of Appeal

12/27, 2014 NLCA 15

Appeal dismissed

Filed documents

The memorandums of argument on an application for leave to appeal will be posted here 30 days after leave to appeal has been granted unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of the memorandum by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613‑996‑7933 or at 1‑888‑551‑1185.

If you have questions about a memorandum of argument or want to use a memorandum of argument, please contact the author of the memorandum of argument directly. Their name appears at the end of the memorandum of argument. The contact information for counsel is found in the “Counsel” tab of this page.

Downloadable PDFs

Not available

The factums of the appellant, the respondent and the intervener will be posted here at least 2 weeks before the hearing unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of factums by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613‑996‑7933 or at 1‑888‑551‑1185.

If you have questions about a factum or want permission to use a factum, please contact the author of the factum directly. Their contact information appears on the first page of each factum.

Downloadable PDFs

Not available

The condensed books of the appellant, the respondent and the intervener will be posted here upon receipt of the electronic version, 2 days prior to the scheduled appeal hearing. You may also obtain copies of condensed books by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613‑996‑7933 or at 1‑888‑551‑1185.

If you have questions about a condensed book or want permission to use a condensed book, please contact the author of the condensed book directly. Their contact information appears on the first page of each condensed book.

Downloadable PDFs

Not available

Webcasts

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Date modified: 2025-02-27