The taxpayer was employed as an instructor at the College of the North Atlantic (the "CNA") on a campus in Qatar ("CNA-Q"). The program the taxpayer taught was designed to prepare students for maintenance and operator positions in the oil industry. More than half of the students were sponsored by local businesses, which covered their full tuition and other costs. Campbell J. found that the taxpayer qualified for a s. 122.3(1) exemption on his income on the basis that the taxpayer worked with respect to "the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources." He reasoned (at para. 22) that the words "with respect to" are inherently broad and stated (at para. 24):
It could be argued that the first stage in the exploitation process must begin with the teaching stage because, unless the relevant skills and knowledge are taught to the professionals that work in these industries, natural resources could not be extracted and eventually sold for profit. The teaching phase for future engineers and technicians is an integral and necessary stage which is preliminary to their involvement in the actual exploration or exploitation process.
Humber (also involving a CNA-Q instructor) was distinguished on the basis that there the connection between CNA's activities and oil exploitation had not been adequately established.
In finding that CNA's business of teaching engineering could also be characterized as being "with respect to an engineering activity" under s. 122.3(1)(b)(i)(B), Campbell J stated (at para. 27) that "the teaching of engineering also constitutes an engineering activity."