b'SETTLEMENT AGREEMENTSThe significant increase in the number of requests forlegislation.TheTribunalhaschosentoexerciseits review received this fiscal year validates the importancejurisdiction by necessary implication on several occa-of prioritizing case management efficiency. The Tribunalsions, for example in theAtkinson v. Canada (Minister hasbeensuccessfulinimprovingefficiencythroughof Public Safety and Emergency Preparedness), 2018 decisions confirming a settlement agreement betweenCART 3.parties.Inordertodoso,theTribunalexercisesnotIn Atkinsononly its exclusive jurisdiction, but also its vested powers, the Tribunal found that it was within its juris-under the principle of necessary implication, as a courtdiction to replace a notice of violation with a penalty by of record. a notice of violation with a warning, in exchange for an admission of responsibility. The Tribunal determined Necessary implication jurisdiction refers to the fact thatby practical necessity that the settlement agreement certain powers are available to the Tribunal in orderwas the most appropriate remedy for the parties.to achieve the objective of the statutory administrativeBy exercising its jurisdiction by necessary implication, monetary penalty regime for agriculture and agri-food.the Tribunal continues to achieve a result that is highly These powers are therefore available to the Tribunalfair, equitable and expeditious to the parties.even if they are not explicitly set out in its enabling Number of Decisions Confirming Settlement AgreementMinister of Public Safety and Emergency Preparedness 4Canada Border Services Agency 2ANNUAL REPORT2018-2019 21'