The Court affirmed a finding below that a company which placed children in foster homes for children's aid societies and assisted the foster parents was making a "re-supply" to the societies of foster care services which it had "acquired" from the foster parents, but that this resupply was not exempt because the company did not satisfy the requirement that its service be provided "in an establishment operated by the supplier for the purpose of providing such service." In rejecting an argument that "establishment" could encompass the business organization of the company, Rennie JA stated (para. 21):
[S]tatutes are to be interpreted so as to give meaning to every term and to avoid redundancy: Placer Dome Canada Ltd v Ontario (Minister of Finance), 2006 SCC 20 at para 45, [2006] 1 SCR 715 at 739, citing Hill v William Hill (Park Lane) Ltd, [1949] AC 530 (HL). If, as contended, an establishment were to be more than the bricks and mortar of the physical building, the third criterion of the test would have been unnecessary - mere surplus language of no consequence.