The applicant physician sought judicial review of a decision by the Inquiries, Complaints, and Reports Committee (ICRC) requiring him to complete a Specified Continuing Education and Remediation Program (SCERP) following several adverse event reports at his clinic.
The applicant argued the decision was unreasonable and the process was procedurally unfair due to skewed chart selection and alleged bias by the College's assessor.
The Divisional Court dismissed the application, finding that the ICRC owed a relatively low degree of procedural fairness which was met, and that its decision was reasonable, justified, and intelligible based on the evidence of poor clinical care and deficient record-keeping.