Law360 Canada ( July 27, 2026, 9:34 AM EDT) -- Appeal by Public Interest Commissioner of Alberta (Commissioner) from a judicial review decision. The fundamental issue in this case was the relationship between the legislative objective of protecting employees who made disclosures and participated in investigations under the Public Interest Disclosure (Whistleblower Protection) Act (PIDA), and the duty of procedural fairness. A disclosure was submitted under PIDA alleging wrongdoing by Campbell, a school division superintendent. The disclosure claimed that Campbell grossly mismanaged employees through systemic bullying, harassment and intimidation. The Commissioner’s office investigated, interviewed employees, provided anonymized investigation summaries to Campbell, and later found wrongdoing. Campbell applied for judicial review of the Commissioner’s report having argued that the Commissioner breached the duty of procedural fairness by not disclosing the identities of the witnesses. The judicial review judge found that the refusal to disclose witnesses’ identities was a breach of the duty of procedural fairness and quashed the Commissioner’s report. On appeal, the Commissioner submitted that the judicial review judge erred in determining the content of the duty of procedural fairness in the circumstances. He submitted that the procedure afforded Campbell was appropriate given the legislative context. Campbell argued that the judicial review judge correctly decided that the procedure was deficient such that there was no need for appellate intervention. Alternatively, if the Court found there was no procedural deficiency, she maintained that the Commissioner’s report should nevertheless be quashed because the investigation was biased and the resulting report was substantively unreasonable....