The applicant, a 76-year-old family physician, sought judicial review of an order by the College of Physicians and Surgeons' Quality Assurance Committee requiring him to practice under clinical supervision.
The order followed peer assessments that identified critical deficiencies in his practice posing an immediate risk to patient safety.
The applicant argued he was denied procedural fairness because he did not receive a copy of the final review before the Committee's initial letter, and that the Committee failed to consider his responses.
The Divisional Court dismissed the application, finding no breach of procedural fairness when the process was viewed as a whole, and concluding that the Committee had properly considered the applicant's submissions.
