LAT dismisses Sami Ibodullo's motion to soften his consent order: a closed file cannot be reopened, and regret is not a ground

Signing a consent order with the Registrar is not a first draft. On August 4, 2026, the Licence Appeal Tribunal dismissed Sami Ibodullo’s motion to amend the consent order that resolved his registration appeal, holding that the Tribunal has no jurisdiction to reopen a closed file on a motion. The decision, published by CanLII as Ibodullo v. Registrar, Motor Vehicle Dealers Act, 2002, 2026 CanLII 80204 (ON LAT), was written by Vice-Chair Genevieve Painchaud after a videoconference hearing on July 29, 2026.

From refusal proposal to consent order

On October 18, 2025, the Registrar issued a Notice of Proposal to refuse Ibodullo’s registration as a motor vehicle salesperson when it came up for renewal. He appealed two days later. A three-day hearing was scheduled for March 11 to 13, 2026, but on February 9 his lawyer withdrew and Ibodullo told the Tribunal he would represent himself.

The hearing never happened. On February 25, 2026, the Registrar advised that the parties had settled, and the next day the Tribunal issued a consent order confirming the terms and conditions document both sides had signed on February 23. Ibodullo waived his right to a hearing, and the hearing dates were vacated. He was back in the trade, on conditions.

One of those conditions bit harder than he expected. Condition 10.B restricts him from dealing with financing: as he described it to the Tribunal, he is “now restricted from explaining, discussing or recommending any financing aspects with customers” ([18]). He is employed as a salesperson but can only perform part of the job. On March 25, 2026, he filed a Notice of Motion asking the Tribunal to remove the words “explain” and “discuss” from the condition.

A closed file stays closed

The motion failed at the threshold. The Registrar argued the Tribunal was functus officio: once it decides a matter, it cannot revisit the decision unless a statute says otherwise or a slip needs correcting, and neither applied. The Vice-Chair agreed. On the document Ibodullo wanted to change, the decision holds that the consent order “is a contract and therefore subject to the laws of contract, therefore final and binding”, and that “dissatisfaction is not enough to unbind a contract” ([22]). Ibodullo did not disagree, and made no submission that the Tribunal had any authority to hear the motion at all.

That left the one escape hatch in the Tribunal’s own rules, and the decision closed it too. Rule 18 allows reconsideration of a final decision if the request is made within 21 days and one of the Rule 18.2 criteria is met: the Tribunal acted outside its jurisdiction or committed a material breach of procedural fairness, made an error of law or fact that would likely have changed the result, or new evidence surfaced that could not have been obtained earlier. Because Ibodullo was self-represented, the Vice-Chair considered whether his motion was simply a reconsideration request filed on the wrong form. It was not: he filed nothing within the deadline even after the reconsideration pathway was explained at a May 26 case conference, and his motion argued none of the criteria. “It was not a matter of using the wrong form. A reconsideration would not have been granted” ([29]).

The decision’s operative order reads “The appeal is dismissed” ([31]). In substance it is the motion that failed: condition 10.B stays exactly as signed, and the consent order that resolved the appeal remains in force.

The consent-order trade-off

Consent orders are how a registrant stops a refusal, suspension or revocation proposal without testing the Registrar’s case at a hearing. Trinity Auto Brokers took that route in July 2026, accepting conditions and a $35,000 letter of credit with no findings made against it. What Ibodullo’s case adds is a plain statement of the cost side: settle, and the Tribunal’s file closes behind you. A registrant who instead lets the appeal run keeps the Tribunal’s remedial powers alive, including the substitution power in s. 9(5) that produced Ali Pourtehrani’s registration on terms the Registrar had never offered. By the time Ibodullo understood what condition 10.B meant on a sales floor, no forum remained with the power to adjust it.

What to learn

• A consent order is a contract, and it is final. The Tribunal will not reopen it because a condition turns out to be commercially painful. Before signing, walk through each condition against a normal working day: if you cannot explain or discuss financing, what parts of your job disappear?
• The reconsideration window is 21 days and needs real grounds. Rule 18.2 of the Tribunal’s rules requires a jurisdictional or fairness defect, a result-changing error, or genuinely new evidence. Regret is not on the list, and the deadline had long passed by the time Ibodullo’s motion was heard.
• Self-representation has procedural costs. Ibodullo settled two weeks after his lawyer withdrew, then fought the aftermath alone. The Tribunal took care to check whether his motion could be saved as a mislabelled reconsideration request, but no form could supply the missing grounds.