The Ministry of Community and Social Services sought judicial review of an Information and Privacy Commissioner order requiring the disclosure of documents related to default hearings under the Family Responsibility and Support Arrears Enforcement Act.
The Ministry claimed exemptions under the Freedom of Information and Protection of Privacy Act, including solicitor-client privilege.
The Divisional Court upheld the Commissioner's decision regarding sections 13, 14, and 18, but found the Commissioner erred in law by concluding that the documents, which were prepared by in-house counsel, lost their solicitor-client privilege once used as guidelines for general application.
The court held the documents were exempt from disclosure under section 19.
