Zündel v. Citron, 2000 CanLII 17137 (FCA)

Ms. Devins is a member of the Canadian Human Rights Tribunal (the Tribunal) that is hearing a complaint brought against Ernst Zündel. At issue in this appeal is whether Ms. Devins is subject to a reasonable apprehension of bias, stemming from a now twelve-year old press release that was issued by the Ontario Human Rights Commission (the Commission or Ontario Human Rights Commission) when Ms. Devins was a member of that Commission, in which the Commission, among other things, applauded a court ruling that found Mr. Zündel to be guilty of publishing false statements that denied the Holocaust.