Because of this, those defending administrative proceedings often ask the administrative decision-maker to exercise its discretion to delay the effective date of any adverse decision in order to facilitate a judicial review. Defendants advance this often as an alternative or secondary position behind their primary position that the administrative proceedings should be dismissed outright. Care must be taken to advance it before the administrator has rendered its decision and become functus: Chandler v. Alberta Association of Architects, 1989 CanLII 41 (SCC), [1989] 2 S.C.R. 848, 62 D.L.R. (4th) 577.
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