This page contains the Applicant’s Amended Book of Authorities (Tabs 1–312) for McLean v. TDHA et al, filed in the Divisional Court in support of the Applicant’s JRPA proceeding. This two‑volume BOA consolidates the complete constitutional, statutory, administrative‑law, insurance‑law, and procedural authorities relied upon across all motions, submissions, and filings in the judicial review. It is the authoritative legal foundation for the Applicant’s position that the Tribunal, TDHA, SNIC, and TDGIC failed to comply with their statutory obligations under the Judicial Review Procedure Act, the Statutory Powers Procedure Act, the Insurance Act, Reg 283, and the SABS.
The BOA includes leading Supreme Court of Canada and Ontario Court of Appeal decisions on administrative fairness, record‑integrity doctrine, prematurity, bias and recusal, statutory interpretation, correctness review, procedural irregularities, and the duties owed by statutory decision‑makers. Authorities such as Payne, Endicott, Jacko, REW, Pritchard, Savone, CIBC Trust, Zurich v. Chubb, Awada, Mansuri, and Heegsma are organized into thematic clusters that support the Applicant’s arguments regarding the Tribunal’s failure to file the Record of Proceeding, the respondent insurance companies’ failure to comply with Rule 68.04(4), and the systemic procedural defects that rendered the JRPA Application ripe for determination.
The BOA also incorporates authorities relevant to the Applicant’s discovery — made possible only after the launch of the Ontario Courts Public Portal in October 2025 — that none of the Respondents had properly filed or delivered Notices of Appearance under Rule 38.07 and Rule 1.03. This revelation is contextualized within jurisprudence on procedural fairness, abuse of discretion, and administrative accountability, demonstrating that the Respondents were not properly before the Court at the time Motions #1 and #2 were brought.
Tabs 1–312 include authorities on: JRPA section 10 obligations; SPPA section 20 content requirements; Reg 283 insurer‑priority rules; SABS compliance; Insurance Act duties; administrative independence; recusal and conflict‑of‑interest doctrine; record‑integrity failures; procedural irregularities; and the Divisional Court’s supervisory jurisdiction. These authorities are cross‑referenced to the Applicant’s Motion Records, Factums, Draft Orders, Compendiums, affidavits, and chronology, allowing the Court to navigate the legal framework with precision.
This page forms part of LawCap’s public‑interest archive documenting administrative law oversight, statutory compliance, record‑integrity doctrine, and the Divisional Court’s supervisory role over the Licence Appeal Tribunal and respondent insurance companies. The Amended Book of Authorities (Tabs 1–312) stands as the definitive legal foundation for the Applicant’s JRPA proceeding, providing the Court with the complete jurisprudential framework required to adjudicate the issues raised in McLean v. TDHA et al.