The appellants appealed decisions granting interlocutory impounding orders for commercial documents seized during tax investigations.
The respondents had challenged the constitutionality of the search provisions under the Charter and sought to have the documents sealed pending a final determination.
The Supreme Court of Canada dismissed the appeal, applying the three-part test for interlocutory relief.
The Court found a serious question to be tried, irreparable harm due to the continuing violation of privacy interests in the respondents' homes and offices, and that the balance of convenience favoured the respondents as the impounding orders would not paralyze the enforcement of taxation laws.
