A decision-maker, known as the Firearms Permit Officer (FPO), has exclusive statutory authorization under theFirearms Permit Act(note this is a fictional statute) to grant permits authorizing a person to have in his/her possession a restricted weapon. TheFirearms Permit Actreads as follows:

90(1) The Firearms Permit Officer (FPO) is responsible for granting all permits authorizing a person to have in his/her possession a restricted weapon.

(2) In assessing whether to grant a permit for possession of a restricted weapon, the FPO will only grant a permit if the weapon is for one of the following reasons:

(a) the protection of life;

(b) for use in connection with his/her lawful profession or occupation; or

(c) for use in target practice in accordance with the conditions attached to the permit.

There is no statutory appeal in the legislation.

Mr. Henry has been hired as a security officer for a local MPP's office. The MPP has been receiving death threats due to his support of continued lockdowns to combat COVID-19. Mr. Henry has previously been a security officer and is well-qualified. He applies under theFirearms Permit Actfor a permit to possess a restricted weapon both for protection of life and for use in connection with his lawful profession.

Mr. Henry's application is denied. When he requests reasons for the denial, the FPO writes a letter that says:

"Your application for a permit to posses a restricted weapon was denied by the local RCMP detachment. Due to the increase in gun violence in your area, we have implemented a new policy that requires all permit applications to be processed by the local RCMP detachment. Under this new policy, I am unable to overturn a decision by the RCMP detachment. I can advise you that you were denied on the basis of the RCMP's new policy to limit the number of permits given in a single month to 5 permits per detachment. We hope that by imposing these limits we can help combat gun violence. I trust you will be understanding."

Mr. Henry asks you for advice on how he can challenge this decision. You tell Mr. Henry that he can seek judicial review of the FPO's decision. WhatTWOerrors wo