In a terrorism prosecution, the applicants sought further disclosure from the Canadian Security Intelligence Service relating to payments made to a human source relied upon in a CSIS affidavit supporting investigative warrants under the Canadian Security Intelligence Service Act.
The court held that records detailing remuneration and reimbursements paid to the source were likely relevant to a pending Garofoli voir dire because financial incentives may affect credibility and the affiant’s assessment of reliability.
Production of records relating to payments to the source was therefore ordered.
However, the request for disclosure of any CSIS reliability assessments concerning a target of the investigation was refused, as the target was not a traditional informant whose reliability required evaluation.
