recommendation and recommended that Quebec judge Michel Girouard should remain on the bench, federal Justice Minister Jody Wilson-Raybould and Quebec Justice Minister Stéphanie Vallée ordered the CJC to reconsider its decision. The CJC has said that misconduct should not guarantee the judge's removal, and the gravity of the misconduct must be determined. Osgoode Hall Law School professor Trevor Farrow said that the rarity of removals reflects the high value that is placed on independence for judges in Canada. Makeup of CJC The CJC is composed only of judges. Galati criticized the makeup of the CJC, pointing out that judges are the only truly self-regulating profession in Canada, and has urged public participation in the process. Osgoode Hall Law School professor Allan Hutchison argued that the CJC should include members of the public, and criticized the hypocrisy of judges calling for natural justice in other professions. University of Calgary Faculty of Law professor and Canadian Association for Legal Ethics president Alice Wooley said including laypersons in the CJC would ensure that the process is less insular and more transparent. Secrecy In September 2003, the Canadian Justice Review Board, a non-governmental advocacy group and "coalition of citizens," expressed concern that the CJC is too secretive. Wooley criticized the CJC for not clearly articulating what constituted misconduct worthy of sanctions. Range of sanctions Some critics have pointed out that the only available sanction of removal may not be appropriate in some circumstances. References External links National councils of the judiciary Legal organizations based in Canada Legal history of Canada 1971 establishments in Canada Organizations established in 1971 1971 in Canadian law