The appellant brought a civil action against the respondent, a psychiatrist who sexually assaulted her when she was a patient.
The respondent sought production of the clinical notes and records of the appellant's subsequent treating psychiatrist.
The Supreme Court of Canada recognized a partial privilege for psychiatric records in civil cases, applying the Wigmore criteria.
The Court upheld the Court of Appeal's order requiring limited disclosure of the records subject to stringent conditions protecting the appellant's privacy.