b'SETTLEMENT AGREEMENTSIn view of the significant increase in theThe Tribunal has exercised its jurisdiction by number of violations under the Tribunalsnecessary implication increasingly since 2018. jurisdiction since 2019 2 , efficiency in caseA notable example is the Atkinson 3decision management must remain a priority. Of allwhere the Tribunal found that it was within strategies implemented, decisions confirmingits jurisdiction to replace a notice of violation a settlement agreement between partieswith a penalty by a notice of violation with have proven their effectiveness. In such cases,a warning, in exchange for an admission the Tribunal exercises not only its exclusiveof responsibility. The Tribunal determined jurisdiction to determine all matters relatingby practical necessity that the settlement to the validity of imposed administrativeagreement was the most appropriatemonetary penalties, but also its vestedremedy for the parties.powers under the doctrine of necessary implication, as a court of record. During the fiscal year 2019-2020, some of the procedures applicable to the settlement Under this doctrine, the Tribunal has certainof cases with the Border Services Agency powers to achieve the purpose of the statutorychanged, though the objective pursued administrative monetary penalty regime forremains the same: ensure a sound and agriculture and agri-food. These powers areexpeditive administration of justice.available to the Tribunal even if they are not explicitly set out in its enabling legislation. By exercising its jurisdiction by necessary implication, the Tribunal continues toachieve the most just and equitableresults for the parties.2 Entry into force of the Safe Food for Canadians Act 3 Atkinson v. Canada (Minister of Public Safety and its Regulations. and Emergency Preparedness), 2018 CART 3.Number of Decisions Conrming a Settlement Agreement2017-2018 2018-2019 2019-2020 2020-2021Minister of Public Safety and Emergency Preparedness 0 4 0 7Canada Border Services Agency 0 2 7 9Canadian Food Inspection Agency 1 0 1 0ANNUAL REPORT 2020-2021 11'