The requester sought access to photos and a video from a closed Crown prosecutor's file under the Freedom of Information and Protection of Privacy Act.
The inquiry officer ordered disclosure, finding that the litigation privilege exemption under s. 19 ended when the prosecution concluded.
The Divisional Court overturned this decision on judicial review.
The Court of Appeal dismissed the appeal, holding that the standard of review was correctness and that the legislative intent of s. 19 was to provide a permanent exemption for Crown counsel's work product, akin to solicitor-client privilege.
