The accused brought an application for disclosure of a police handler's handwritten notes regarding a confidential informant.
The accused sought the notes to determine whether the informant's information was firsthand, arguing this was necessary to challenge a subsequent warrantless search.
The Crown opposed the application, asserting informer privilege and arguing the information was irrelevant as the reliability of the informant had already been established in a prior ruling.
The court dismissed the application, finding that because the value and reliability of the informant's information had already been determined in a previous Garofoli application, the handler's notes were no longer relevant.
