The following excerpt is from Bethany Care Centre v. United Nurses of Alberta, Local No. 91, 1983 ABCA 226 (CanLII):
Is there to be a disqualification on the grounds of apprehension of lack of independence? Is it reasonable to assume, to suspect, that the employee of the parent Union will not readily displease his employer? He or she has an economic interest in sustaining the good will of that employer. The grievor is a member of that employer. One of the employer's objects is to promote the welfare of nurses, a highly relevant consideration in a policy dispute. Can the other party say, with confidence,: here is someone partial, but independent? The answer is no. Employees are normally expected to favour their employer's interests: Guimond v. Sornberger et al (1980), 25 A.R. 19.
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