The appellant insurer issued a life insurance policy to the respondent's son, which included a supplementary indemnity for accidental death but excluded suicide.
The insured signed an authorization allowing the insurer access to his medical records for risk assessment and loss analysis.
After the insured was found drowned, the insurer suspected suicide and sought access to his medical records from the hospital, which refused.
The Supreme Court of Canada held that the authorization constituted a valid waiver of confidentiality, entitling the insurer to the complete medical records to investigate the cause of death.
The Court ordered the hospital to release the records pursuant to article 402 of the Code of Civil Procedure.
