The court initiated a Rule 2.1 review, at the request of the Ontario Provincial Police, to consider dismissing the plaintiff's action against the Toronto Police Service and Ontario Provincial Police.
The plaintiff's claim alleged police inaction in investigating harassment.
The court found grounds to believe the action was frivolous, vexatious, or an abuse of process against these two defendants due to a lack of factual involvement and issues of vicarious liability under the Police Services Act.
The plaintiff was given 15 days to file a written submission in response, and the proceeding was stayed pending the resolution of the Rule 2.1 process.