The Royal Commission of Inquiry into the Confidentiality of Health Records in Ontario sought to compel RCMP officers to disclose the identities of physicians and hospital employees who had provided patients' medical information to the police without authorization.
The officers claimed police-informer privilege.
The Supreme Court of Canada held that the police-informer privilege is a rule of law that applies generally, including in civil proceedings and public inquiries, to protect the identity of those who furnish information to the police in the course of their duties.
The privilege belongs to the Crown and is not defeated by the fact that the informants may have breached a duty of confidentiality in providing the information.
The appeal was allowed and the officers were not required to disclose the identities.
