The Attorney General of Canada applied under section 38.04 of the Canada Evidence Act to confirm the prohibition of disclosure of sensitive information withheld from the Certified Tribunal Record in the respondent's underlying application for mandamus regarding his long-delayed citizenship application.
Applying the Ribic test, the Court accepted the Attorney General's proposals for additional disclosure by way of lifts, summaries, and factual stipulations, finding that this would provide the respondent a clear understanding of the narrative of events and allow him to meaningfully advance his case.
The Court concluded that the remaining withheld information, while relevant, would cause injury if disclosed, and that the public interest in non-disclosure outweighed the public interest in further disclosure.
The prohibition on disclosure of the remaining redacted information was confirmed.
