The appellant was convicted of aggravated assault.
He appealed on the basis that the Crown failed to disclose statements made by four individuals, although summaries were included in police reports provided to defence counsel.
Applying the principles from a companion case, the Supreme Court of Canada dismissed the appeal.
The Court found that the undisclosed statements had very low materiality and that defence counsel failed to exercise due diligence by not requesting the full statements despite knowing of their existence.
Consequently, the failure to produce the statements did not affect the fairness of the trial process.
