Several police officers sought judicial review of a decision by the Toronto Police Services Board granting the Chief of Police an extension of time to serve notices of disciplinary hearings under s. 69(18) of the Police Services Act.
The officers argued that the Board breached procedural fairness by failing to provide full disclosure of the investigative brief, denying an oral hearing, and providing inadequate reasons.
The Divisional Court dismissed the applications, finding that the Board's procedure met the minimal requirements of fairness for an administrative, pre-charge decision and that the Board's decision to allow the delay was reasonable given the unprecedented complexity of the underlying criminal investigation.