While this concept of reasonableness applies to any judicial review of an adjudicator's determination whether or not an infraction of a Township bylaw has occurred, there remains some controversy as to what standard of review might apply when the adjudicator's decision is being challenged for breach of a duty of procedural fairness. This is discussed in Hefnawi v. Health Care Practitioners Special Committee for Audit Hearings, 2016 BCSC 226 at paras. 63–67, which noted:
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