The accused was charged with sexual offences against a four-year-old child.
During a voir dire into the admissibility of a video-recorded police interview with the child complainant, the defence brought a motion for further Crown disclosure seeking police training materials, policy manuals, and information regarding the interviewing officer's training in child interrogation techniques.
The Crown argued these materials were not in its possession and control, and that the defence should pursue a third-party records application.
The court granted the motion in part, ordering disclosure of police-wide standards, policies, and protocols governing child interviews, but refusing disclosure of general training and reference materials.