Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107 -- summary under Perpetual Obligations

Sharlow J.A. stated (at p. 6260) that "it requires clear and explicit statutory language to deprive ... a person of recourse to the minimal protection afforded by the right to seek judicial review of the exercise of the Minister's discretion" after expressing "considerable discomfort with the notion of a statutory obligation that may exist in perpetuity, subject only to the discretion of the Minister", which was the case with respect to assessments under s. 160 of the Act.