b'SETTLEMENTAGREEMENTSTheincreaseinrequestsforrevisionreceivedinTheTribunalhaschosentoexerciseitsjurisdiction 2019-2020 was sustained and once again validatesbynecessaryimplicationonseveraloccasions,for the importance of prioritizing efficient case manage- example in the Atkinson 6decision. In the past year, ment.TheTribunalhasbeensuccessfulinimprov- some of the procedures applicable to the settlement of ing efficiency through decisions confirming a settle- cases with the Border Services Agency have changed, ment agreement between parties. In order to do so,but the objective pursued remains the same: the sound the Tribunal exercises not only its exclusive jurisdic- administration of justicetion, but also its vested powers under the principle ofIn Atkinson, the Tribunal found that it was within its juris-necessary implication, as a court of record. diction to replace a notice of violation with a penalty by Necessary implication jurisdiction refers to the fact thata notice of violation with a warning, in exchange for an certain powers are available to the Tribunal in orderadmission of responsibility. The Tribunal determined to achieve the objective of the statutory administrativeby practical necessity that the settlement agreement monetary penalty regime for agriculture and agri-food.was the most appropriate remedy for the parties.These powers are therefore available to the TribunalBy exercising its jurisdiction throught necessary impli-even if they are not explicitly set out in its enablingcation, the Tribunal continues to achieve a result that is legislation.fair, equitable and expeditious to the parties.6. Atkinson v. Canada (Minister of Public Safety and Emergency Preparedness), 2018 CART 3.Number of Decisions Confirming Settlement Agreement*2018-2019 2019-2020Minister of Public Safety and Emergency Preparedness 4 0Canada Border Services Agency 2 7Canadian Food Inspection Agency 0 1* The first settlement agreements took effect in the 2018-2019 fiscal year.ANNUAL REPORT 2019-2020 19'