The applicant, a chartered accountant, sought judicial review of a decision by the Institute of Chartered Accountants of Ontario's Discipline Committee finding him guilty of professional misconduct for failing to cooperate with an investigation.
The investigation stemmed from a complaint that the applicant helped a client conceal income in a matrimonial dispute.
The applicant argued that the investigating committee breached its duty of fairness by expanding the investigation without notice and breached its disclosure obligations by not providing the preliminary investigative report.
The Divisional Court dismissed the application, finding no evidence that the investigation had expanded and holding that there was no obligation to disclose the preliminary report during an ongoing investigation.