The applicant, a member of the Ontario College of Teachers, sought judicial review of a decision by the College's Discipline and Fitness to Practise Committees to amend their rule regarding third-party record production to align with R. v. Mills.
The Divisional Court dismissed the application, finding that the applicant lacked both private and public interest standing as he was not currently subject to any proceedings where the rule would apply.
Furthermore, the Court held that even if standing were established, the Committees' decision to update the rule was reasonable and within their statutory authority.