Does a municipal council owe procedural fairness when dealing with planning matters at public hearings?

Municipal councils owe a duty of procedural fairness when dealing with planning matters at public hearings. The rules of natural justice apply but their content depends on a number of factors: “including the terms of the statute pursuant to which the body operates, the nature of the particular function of which it is seized and the type of decision it is called upon to make”. (Old St. Boniface Residents Assn. Inc. v. Winnipeg (City), 1990 CanLII 31 (SCC), [1990] 3 S.C.R. 1170, [1990] S.C.J. No. 137 at para. 44). In Old St. Boniface, the appellant had relied on Wiswell v. Metropolitan Corporation of Greater Winnipeg, 1965 CanLII 106 (SCC), [1965] S.C.R. 512, but Sopinka, J. said in para. 44: Wiswell must be read in light of comparatively recent changes that have occurred in applying the rules of natural justice.