The accused brought a bail review application after being detained by a justice of the peace on the secondary ground under s. 515(10)(b) of the Criminal Code.
The court found a material change in circumstances due to a significantly revised bail plan with new proposed sureties and also noted a misapprehension regarding the number of charges at the original hearing, permitting a de novo review.
While the court concluded detention was not justified on the primary or tertiary grounds, it held that the accused failed to meet the reverse onus on the secondary ground.
Concerns about credibility, extensive prior convictions for crimes of dishonesty, and the weakness and impracticality of the proposed surety supervision plan created a substantial likelihood of further offences or interference with the administration of justice.
