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Case Title & Citation
Friends of the Oldman River Society v. Canada (Minister of Transport), [1992] 1 S.C.R. 3. -
Decision Summary (Neutral Overview)
This case involved a proposed dam project on the Oldman River in Alberta. Environmental groups argued that federal authorities had to conduct an environmental assessment before approving the project.
The Supreme Court ruled:
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Federal authorities were subject to the federal Environmental Assessment and Review Process Guidelines Order.
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The Minister of Transport had to consider environmental factors and follow the required process before approving works.
The decision emphasized that statutory and regulatory duties apply fully to government projects.
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Historical & Legal Context
Oldman River arose at a time when environmental law and federal-provincial division of powers were in flux. The case consolidated the principle that governments must follow their own legal frameworks and cannot exempt themselves informally. -
Key Legal Principles Identified in the Case
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Environmental assessment requirements are binding on the Crown.
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Failure to follow mandatory procedures can invalidate approvals.
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Courts can review compliance with such duties.
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Implications for Haldimand, Loyalist, and Mohawk Questions
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Oldman River provides a template for insisting that all relevant legal frameworks—including Haldimand and related instruments—must be taken into account before development proceeds on the Grand River.
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Just as the Crown cannot skip environmental obligations, it cannot legitimately ignore constitutional and quasi-international obligations toward Mohawk posterity when approving roads, subdivisions, or industrial projects.
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Points of Interest to Mohawk of Grand River Posterity
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The case reinforces that procedural obligations are not optional; they bind governments even when projects seem economically or politically important.
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It supports demands that any assessment of projects on Haldimand lands must begin by acknowledging who the land was purchased for and what obligations were attached.
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Unresolved Questions / Future Research Directions
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Could courts require a “Haldimand impact assessment” analogous to environmental assessment, as part of Crown honour and fiduciary duties?
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How far would Oldman River’s logic reach if the omitted framework is not environmental law but the Haldimand/Dorchester system?
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Sources
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Friends of the Oldman River Society v. Canada (Minister of Transport), [1992] 1 S.C.R. 3.
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Federal environmental assessment materials and commentary.


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