In the wake of COVID-19, which has strained already limited judicial resources, the Alberta Court of Appeal has issued a decision addressing the need for judicial economy and the avoidance of duplicative and overlapping proceedings in multijurisdictional class actions.
On November 27, 2020, the Alberta Court of Appeal in Ravvin v Canada Bread Company, Limited, 2020 ABCA 424 (CanLII), http://canlii.ca/t/jbv75, confirmed the jurisdiction of a case management judge to grant a stay of proceedings pursuant to section 5 of the Class Proceedings Act prior to hearing the certification application. In support of its decision, the Court emphasized the importance of judicial economy, one of the three public policy objectives of class proceedings.
The actions underlying the appeal were two of twelve proposed class proceedings across Canada commenced against a group of retailers alleging a price-fixing conspiracy involving packaged bread. At the time of the hearing, stays had been granted in the Federal Court, Alberta, and Manitoba in favour of permitting an Ontario action, which had been filed earlier, to proceed. Ravvin appealed on 13 grounds that the Court grouped into two issues:
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