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Solicitor-client privilege was not clearly displaced by the production power.
An access-to-information appeal considered whether statutory language allowing production despite any privilege of the law of evidence authorized a provincial privacy commissioner to compel records claimed as solicitor-client privileged.
The Court held that the provision did not clearly and unequivocally abrogate solicitor-client privilege in its substantive dimension.
Reading the statute as a whole, the Court found no clear legislative intent to set aside that privilege.
The appeal was dismissed, and the order compelling production was not upheld.
