Fee et al. v. Bradshaw et al., 82 DTC 6264, [1982] CTC 201, [1982] 1 SCR 607 -- summary under Subsection 244(4)

S.18 of the Federal Court Act does not give the Federal Court the jurisdiction to prohibit the filing of an allegedly false certificate, because neither (1) the statement in a certificate of the day on which the evidence came to the Minister's knowledge nor (2) the filing of a certificate, entails a decision of an administrative nature or the exercise of a discretionary power. Those actions instead are to be regarded respectively, as (1) a simple statement of fact and (2) the use of a mode of proof. "Only to the extent that he makes an administrative decision or exercises a discretionary power could it be argued that the Minister of National Revenue ... may be subject to the superintending and reforming power of the Trial Division".