Yes, it would probably constitute a forbidden combination if it was a petition created by a group of service members. If it was created and signed by civilians, however, then there should be no issue.
Perhaps
@FJAG has an opinion on the legality of service members signing a civilian petition requesting changes to CAF policies, or if this was initiated by a service member reaching out to their MP.
The QR&O is straightforward in its wording and easy to understand.
Who created the petition is irrelevant. What is relevant is that a) the petition attempts to alter an existing regulation and that b) all those signing are combining to advocate that change through the joint petition.
How many civilians sign it are signing it is irrelevant as well. One could argue that if only one member signed the petition then that member would not be in contravention of the QR&O. IMHO, however, the moment a second (or more) member signs then they are both (all) in contravention of QR&O 19.10b.
There is a deeper question, however, which is whether QR&O is in contravention of Section 2(d) of the Charter of Rights and Freedoms "freedom of association," or whether it is a "reasonable limit prescribed by law as can be demonstrably justified in a free and democratic society."
I won't do a legal analysis or offer a legal opinion as I've stopped practicing law some 16 years ago. But I'll offer a gut reaction. I think the QR&O is overbroad.
Overbreadth analysis looks at the means chosen by the state in relation to its purpose. A court must consider whether those means are necessary to achieve the state objective. If the state, in pursuing a legitimate objective, uses means which are broader than is necessary to accomplish that objective, the principles of fundamental justice will be violated because the individual's rights will have been limited for no reason. The effect of overbreadth is that in some applications the law is arbitrary or disproportionate. - R v Heywood [1994] 3 SCR 761
Note that this QR&O goes far beyond the mutiny service offences in ss 79-81 of the NDA which, IMHO, are perfectly valid under the Charter.
The QR&O on the other hand goes much further and is aimed at restraining the exact right that s2(d) of the Charter grants to all citizens. The QR&O does not describe what state objective the QR&O is designed to achieve which would make its broad wording a proper "reasonable limit" that the Charter might permit. I can speculate why the QR&O is there but that would merely set up a number of strawman arguments. I won't attempt to do that.
All that said, a member signing the petition would be at risk of being charged with a breach of the QR&O and then would have to mount a significant legal challenge at any trial. A member would need to determine if this is the hill they are prepared to fight for.
