The appellant was convicted of aggravated assault following a group beating.
The Crown inadvertently failed to disclose four witness statements, though summaries were included in police occurrence reports provided to defence counsel during the trial.
The Supreme Court of Canada held that while the Crown breached its duty to disclose relevant material, the appellant's right to make full answer and defence was not impaired.
The undisclosed statements would not have affected the reliability of the conviction, and defence counsel's lack of due diligence in pursuing the full statements after receiving the summaries was a significant factor in concluding that the overall fairness of the trial process was not compromised.
