The appellant lawyer was subject to disciplinary proceedings by the provincial law society.
He challenged the constitutionality of a provision in the Law Society Act that allowed the society to award costs of an investigation against a lawyer found guilty of professional misconduct, arguing it created a pecuniary interest and a reasonable apprehension of bias violating section 7 of the Charter.
The Supreme Court of Canada held that the costs provision did not contravene the principles of fundamental justice, as the recouped costs were reimbursements for expenses, not profits, and any pecuniary interest of the committee members was too remote to give rise to a reasonable apprehension of bias.
The appeal was dismissed.
