I would hope to try to ground it in the Montfort case and build from some broader principle than purely administrative law. I think that case opened some interesting doors with respect to the rule of institutions in communal life and a sense of well-being.
I worried that someone might ask me the question you just asked, and I'm going to be honest about why I worry about it. The federal government is pretty much locked into its official languages policy, constitutionally and otherwise. It extends to services beyond section 133. If there is federal support for attacks on the administrative procedures of the provinces, my bet is that the average province is going to double down on making its administrative procedures bullet-proof. Or they may try to remove the underlying right under provincial jurisdiction, such that you don't even have to worry about the administrative problem anymore.
We're all struggling to get the provinces themselves to establish rights. If the minute they do it, we turn around and beat them with a baseball bat under the Court Challenges Program, it may be counterproductive. Let's get the rights, and let's get them working. There's lots of stuff to work on right now. Once we have a culture that has come to some consensus on these items, then you can start to talk about fair administrative practices and perhaps court challenges. But I'm reluctant to encourage you to go there, because I think you may put at risk the whole program.