An Ontario court held in The Professional Institute of the Public Service of Canada v. Canada (Attorney General), 2014 ONSC 965 (CanLII) that the federal Expenditure Restraint Act was not contrary to the freedom of association of unionized employees under s. 2(d) of the Canadian Charter of Rights and Freedoms. The Act placed limits on wage increases that could be negotiated in collective bargaining for a specified period; its goal was to restrict federal wage increases in the public service as a whole. If there was a breach of the freedom of association through a breach of any right to collective bargaining or otherwise, it was a breach that could be and had been demonstrably justified.
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