A World That Has Walls: A Charter Analysis of Military Tribunals
RUBSUN HO
ABSTRACT
Military tribunals have evolved as a parallel system of justice that
is generally insulated from civilian influence. In recent months, however,
an increasingly intense public spotlight has focused on the practices
of the Canadian military and alarmed civilians have questioned many
of its traditional procedures. It has become clear that the Canadian
Armed Forces can no longer operate in a vacuum. The advent of the Canadian
Charter of Rights and Freedoms has put increasing pressure on the military
to modify its judicial regime to conform with the values and guarantees
advocated in the post-Charter era. In one of the rare military appeals
considered by the Supreme Court of Canada, R. v. Genereux, the Court
acknowledged the importance of a separate system of military justice,
but also emphasized that such a system must accommodate Charter rights
and freedoms. While s.11(f) of the Charter specifically denies the right
to trial by jury to those who are tried by military tribunals, the principles
underlying the conduct of a jury trial can serve as a useful benchmark
in gauging the fairness of proceedings within the military justice system.
In this article, the author examines military tribunals in the light
of the minimum standards of fairness in criminal proceedings that are
guaranteed in ss.7 and 11(d) of the Charter. The author argues that
certain procedures used by military tribunals do violate the standards
of fairness embodied in these sections, and that these violations cannot
be justified under s.1 of the Charter.
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Citation: (1996) 54(1) U.T. Fac. L. Rev. 149.
Copyright © 1996. University of Toronto Faculty of Law Review.
All rights reserved.