Savoie v. Canada (Public Safety and Emergency Preparedness), 2022 FC 333

Case Summary

The applicant sought judicial review of a decision by the RCMP to withhold records relating to the investigation of a fatal motor vehicle accident involving her daughter. The RCMP disclosed a small portion of the records but withheld the balance under subparagraph 16(1)(a)(ii) of the Access to Information Act. The Federal Court conducted a de novo review and determined that the records fell within the statutory exemption as they were obtained in the course of a lawful investigation and were less than 20 years old. The Court further held that the RCMP reasonably exercised its discretion in refusing to disclose the records on compassionate grounds.