What is the test for the doctrine of functus officio?

Manitoba, Canada


The following excerpt is from Westman v. Gyselinck, 2014 MBQB 174 (CanLII):

The majority decision written by Sopinka J. in Chandler v. Alberta Association of Architects, 1989 CanLII 41 (SCC), [1989] 2 S.C.R. 848, is the leading case with respect to the doctrine of functus officio. Sopinka J. states, at p. 867: The doctrine of functus officio states that an adjudicator, be it an arbitrator, an administrative tribunal, or a court, once it has reached its decision cannot afterwards alter its award except to correct clerical mistakes or errors arising from an accidental slip or omission …

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