forced Royal Oak Mines to return to the negotiation table with a previously withdrawn proposal. Royal Oak Mines sought judicial review of this order, with the dispute winding its way through the court system during the first half of the 1990s. This set the stage for significant changes in Canadian labour law as evident in the Supreme Court's 1996 decision in Royal Oak Mines v. Canada (Labour Relations Board), [1996] 1 S.C.R. 369. In his majority decision Mister Justice Peter Cory formulated a distinction between the subjective and objective aspects of the duty to bargain. A 'good faith' requirement forms the subjective aspect of this duty, while a requirement to 'make every reasonable effort' to conclude a collective agreement injects an objective standard into the analysis. In this decision Royal Oak Mines was compelled to return to the bargaining table on the basis that its refusal to discuss grievance arbitration with the Canadian Association of Smelter and Allied Workers, Local No. 4, constituted an unreasonable limitation on the bargaining process and thereby represented a lack of good faith. In coming to this conclusion the Court observed that grievance arbitration for dismissed employees was a nearly universal characteristic of collective agreements in Canada. References Defunct mining companies of the United States Canadian Auto Workers Mining in Canada Defunct mining companies of Canada 1900 establishments in Washington (state) Mass murder in Canada Mass murder in 1992 1992 murders in Canada Massacres in Canada