The appellants sought to quash a search warrant executed at a legal aid bureau to seize a legal aid application form.
The police alleged the applicant falsely reported his income to obtain legal aid.
The Supreme Court of Canada held that while solicitor-client privilege is a substantive right that arises as soon as a potential client approaches a law firm, communications that are criminal in themselves (such as falsely stating income to fraudulently obtain legal aid) fall under an exception and are not privileged.
The Court affirmed the justice of the peace's jurisdiction to issue the warrant but emphasized that strict procedures must be followed to protect confidential information when searching a lawyer's office.
The appeal was dismissed.
