Minister of National Revenue v. Coopers and Lybrand, 78 DTC 6528, [1978] CTC 829, [1979] 1 SCR 495 -- summary under Section 28

The following criteria were formulated for the purpose of determining whether a decision or order is one required by law to be made on a judicial or quasi-judicial basis: (1) is the holding of a prior hearing impliedly contemplated? (2) does the decision or order directly or indirectly affect the rights and obligations of persons? (3) is the adversary process involved? (4) is there an obligation to apply substantive rules to many individual cases (as opposed to there being a broad policy mandate)?