b'SETTLEMENT AGREEMENTSOf all strategies implemented, decisions confirmingIn view of the significant increase in the number a settlement agreement between parties haveof violations under the Tribunals jurisdiction since proven their effectiveness. In such cases, the2019,3 efficiency in case management must remain Tribunal exercises not only its exclusive jurisdictiona priority. The Tribunal has exercised its jurisdiction to determine all matters relating to the validity ofby using the doctrine of necessary implication imposed administrative monetary penalties, but alsoincreasingly since 2018. A notable example is the its vested powers under the doctrine of necessaryAtkinson4 decision where the Tribunal found that implication,2 as a court of record. it was within its jurisdiction to replace a notice of violation with a penalty by a notice of violation Under this doctrine, the Tribunal has certainwith a warning, in exchange for an admission powers to achieve the purpose of the statutoryof responsibility. The Tribunal determined by administrative monetary penalty regime forpractical necessity that the settlement agreement agriculture and agri-food. These proceduralwas the most appropriate remedy for the parties.powers are available to the Tribunal even if they are not explicitly set out in its enabling legislation.By exercising its jurisdiction by using the doctrine The objective pursued remains the same: ensure aof necessary implication, the Tribunal continuessound and expeditious administration of justice. to achieve the most just and equitable results for the parties.2Common law doctrine referring to implications that are so highly probable that drawing any otherinference from the facts would appear unreasonable. 3Entry into force of the Safe Food for Canadians Act and its Regulations. 4Atkinson v. Canada (Minister of Public Safety and Emergency Preparedness), 2018 CART 3. Number of Decisions Conrming a Settlement Agreement2017-2018 2018-2019 2019-2020 2020-2021 2021-2022Minister of Public Safety and0 4 0 7 3Emergency PreparednessCanada Border Services Agency 0 2 7 9 1Canadian Food Inspection Agency 1 0 1 0 011'