Nanda v. Oakville (Joint Compliance Audit Committee)

canada, canadian, case law, court opinion, canlii, onca, 2026onca638, 2026 onca 638 (canlii), 2026, onca, 638, (canlii), coa-25-cv-0413, 2026, municipalities, municipal elections, compliance audit regime, municipal elections act, 1996, s. 88.33(1), who can apply for a compliance audit where the municipality is divided into wards, whether any elector eligible to vote in the municipal election has standing regardless of ward, committee jurisdiction to order audit, appeal allowed, committee decision reinstated, statutory interpretation, presumption of consistent expression, context within statute, municipal elections act, 1996, s. 19(7), s. 88.33(1), whether s. 19(7) limits standing to electors entitled to vote for the candidate, reliance on voting, ward provision to interpret audit standing rejected, section 19(7) held not determinative, appeal allowed, statutory interpretation, modern approach, public welfare legislation, municipal elections act, 1996, s. 88.33(1), how text, context and purpose determine meaning of “entitled to vote in an election”, remedial objective of transparency, accountability and public confidence in elections, narrow reading rejected as unduly restricting scrutiny, appeal allowed, procedure, statutory screening threshold, reasonable grounds, municipal elections act, 1996, s. 88.33(1), whether the “reasonable grounds” requirement is a meaningful safeguard against frivolous complaints and “officious intermeddlers”, committee must be satisfied on compelling and credible information before ordering audit, safeguard held sufficient, appeal allowed