The Ontario Securities Commission (OSC) investigated Philip Services Corporation for inadequate financial disclosures.
During the investigation, the OSC compelled documents and testimony from Deloitte & Touche LLP, Philip's auditors.
The OSC subsequently commenced proceedings against Philip and its officers and ordered the disclosure of the compelled material from Deloitte to Philip, finding it in the public interest to do so.
Deloitte appealed the disclosure order.
The Supreme Court of Canada dismissed the appeal, holding that the OSC's decision to order disclosure was reasonable.
The OSC properly applied the Stinchcombe relevance standard and balanced Deloitte's privacy interests against the respondents' right to make full answer and defence.
