WARNING
The court hearing this matter directs that the following notice be attached to the file:
This is a case under Part V of the Child, Youth and Family Services Act, 2017, (being Schedule 1 to the Supporting Children, Youth and Families Act, 2017, S.O. 2017, c. 14), and is subject to subsections 87(7), 87(8) and 87(9) of the Act. These subsections and subsection 142(3) of the Act, which deals with the consequences of failure to comply, read as follows:
- (7) Order excluding media representatives or prohibiting publication.—Where the court is of the opinion that the presence of the media representative or representatives or the publication of the report, as the case may be, would cause emotional harm to a child who is a witness at or a participant in the hearing or is the subject of the proceeding, the court may make an order,
(c) prohibiting the publication of a report of the hearing or a specified part of the hearing.
(8) Prohibition re identifying child.— No person shall publish or make public information that has the effect of identifying a child who is a witness at or a participant in a hearing or the subject of a proceeding, or the child’s parent or foster parent or a member of the child’s family.
(9) Prohibition re identifying person charged.— The court may make an order prohibiting the publication of information that has the effect of identifying a person charged with an offence under this Part.
142.—(3) Offences re publication.— A person who contravenes subsection 87(8) or 134(11) (publication of identifying information) or an order prohibiting publication made under clause 87(7)(c) or subsection 87(9), and a director, officer or employee of a corporation who authorizes, permits or concurs in such a contravention by the corporation, is guilty of an offence and on conviction is liable to a fine of not more than $10,000 or to imprisonment for a term of not more than three years, or to both.
CITATION: Children’s Aid Society of Toronto v. K.Y., 2025 ONCJ 623
COURT FILE NO. 24-222
DATE: December 1, 2025
ONTARIO COURT OF JUSTICE
BETWEEN:
CHILDREN’S AID SOCIETY OF TORONTO
APPLICANT
Lucia Spampinato,
Counsel for the APPLICANT
- and -
K.Y.
RESPONDENT MOTHER
Preeti Yadav and
Daljit Mann,
Counsel for the RESPONDENT MOTHER
- and –
Y.S.
RESPONDENT FATHER
Helen Kavouras Lopes and
Elena Kurgatnikov Miller,
Counsel for the RESPONDENT FATHER
- and –
S.C.
RESPONDENT
KITH CAREGIVER
Self- Represented
- and-
L.B.
RESPONDENT
KITH CAREGIVER
Self-Represented
OFFICE OF THE CHILDREN’S LAWYER
Zahra Taseer,
Counsel for the Child, S.S.
HEARD: October 23, 2025
JUSTICE J. HARRIS
RULING ON THE VOIR DIRE
INTRODUCTION AND ISSUES
1This is a ruling on a voir dire held in a trial of this proceeding brought by the Children's Aid Society of Toronto (the “CAST”).
2On the first day of trial, October 21, 2025, the Father raised a concern about the admissibility of evidence from the Office of the Children’s Lawyer (“OCL”) Clinician.
3This voir dire hearing was scheduled to determine the admissibility of evidence from the OCL Clinician in view of a potential conflict of interest between the roles of the witness as both the OCL Clinician and a full-time paid employee of the CAST.
4At the voir dire, this Court heard evidence from the Current Family Services Worker and the OCL Clinician and received submissions from all parties.
5On October 23, 2025, this Court decided the issue in court and advised that written reasons would follow. These are the written reasons.
POSITION OF THE PARTIES
6The OCL took the position that there was no actual conflict of interest and any perception, if any, of a conflict of interest, should be mitigated by the surrounding circumstances and the importance of hearing the Child’s voice.
7The OCL submitted that there are no cases that are similar in facts and submitted that this is an analogous situation to a conflict of interest amongst lawyers and relied on Canadian National Railway Co. v. McKercher LLP, 2013 SCC 39. The OCL took the position that denying the OCL Clinician’s evidence would remove the Child’s independent voice in this proceeding, the Court has an obligation to the Child, not the parents, and that the Court has to hear from the Child. However, if the Court were to exclude this evidence, the OCL suggested that the Child could be called as a witness to give evidence or participate in a judicial interview, although neither option was considered ideal by the OCL.
8The CAST took a similar position, that there is no actual conflict of interest, and any perception of bias is mitigated by the surrounding circumstances.
9The Kith Caregivers took the position that there is no conflict of interest and that it is really important that the Child’s thoughts be included through the evidence of the OCL Clinician. The Kith Caregivers submitted that all opportunities to hear the Child’s voice are very important for this Court.
10Each of the Mother and Father took the position that there is a conflict of interest, and the Court should not admit the evidence from the OCL Clinician.
11The Mother submitted that the OCL is supposed to be an organization independent from the CAST. Mother’s counsel submits that the OCL Clinician has a duty of loyalty to her current employer, the CAST, resulting in her involvement as OCL Clinician lacking the necessary independence.
12The Father submitted that it is very important for the Child to have a voice, and equally or more important for all parties to know that those views and preferences are completely unbiased. The Father submitted that this issue should have been out in the open and that it came to light only because Father’s counsel had personal knowledge that the OCL Clinician was also an employee of the CAST.
FACTS
13On June 3, 2024, a protection application was issued. The CAST sought a final six-month order placing the Child in the care and custody of the Kith Caregivers, subject to the supervision of the CAST for six months without terms and conditions.
14On January 30, 2025, the CAST indicated its intention to amend its application to seek a deemed custody order pursuant to section 102 of the Child, Youth and Family Services Act, 2017, SO 2017, c 14, Sch 1 (“CYFSA”). On that date, pursuant to section 78 of the CYFSA, an order was made appointing the OCL.
15By April 29, 2025, Ms. Taseer was the assigned OCL.
16On June 27, 2025, the Father was granted two weekly virtual access visits with the Child. The OCL, the CAST and the Kith Caregivers opposed this order. The Mother consented to the access order. The matter was scheduled for trial in the October sittings.
17On August 18, 2025, the OCL Clinician was assigned to the file.
18On September 8, 2025, the Paternal Grandmother brought a motion to be added as a party and for access with the Child for herself, the Paternal Grandfather and the Paternal Aunt.
19The OCL Clinician and the Current Family Services Worker filed evidence, and both attended at that motion. The CAST, the OCL, and the Kith Caregivers opposed the motion.
20The Paternal Grandmother’s motion was dismissed.
EVIDENCE OF THE OCL CLINICIAN
21During the voir dire, the OCL Clinician gave evidence that she has been working with the OCL for 11 years, which she incorrectly stated was since 2011.
22The OCL Clinician gave evidence that she is also a full-time paid employee of the CAST and has worked for the CAST for 27 years. She currently works as an intake worker.
23In the voir dire, the OCL Clinician testified that her access to the Child Protection Information Network (“CPIN”) is limited to those cases that are assigned to her. Otherwise, she would need to request disclosure “like anyone else would” through the disclosure unit, and she would not be able to access any information that would not be “privy for her.”
24During cross-examination, the OCL Clinician testified that she has full access to CPIN, she could have access to any children’s aid society files as long as they were on CPIN, but there is a policy that she is not supposed to use CPIN to search cases except for cases to which she is assigned specifically.
25The OCL Clinician testified that she did not look up in CPIN any information for this CAST file, and did not participate in CAST’s internal planning meeting, and was not part of the CAST planning for trial.
26The OCL Clinician testified she did not perceive a conflict of interest when she was assigned to this case and, further, that her supervisors and directors have told her that her work for CAST and her work for the OCL complement each other.
27Under cross-examination, the OCL Clinician testified that, in the past, she had stopped her work for the OCL on certain other files due to involvement with the children’s aid society, such as a situation where she reported information to a children’s aid society and an investigation was launched.
28The OCL Clinician testified that she had not met the Current Family Services Worker. However, during examination of the Current Family Services Worker, the evidence differed. In particular, the Current Family Services Worker testified that they had met and provided credible details about reading the OCL Clinician’s affidavit, recognizing the name, and taking steps to confirm it is the same person who she had met.
29The OCL Clinician testified as follows:
a) at the OCL, her supervisor at the OCL knows that she is on this case and that she also works for the CAST;
b) at the CAST, her supervisor does not know that she is the OCL Clinician on this case;
c) at the CAST, she is not aware of any ethical wall at the CAST or any restrictions on her ability to access this file in CPIN;
d) for purposes of getting a better understanding of the background of the file, she had reviewed the pleadings, the CAST affidavit, as well as a letter from a counsellor providing services for the Child;
e) she did not share with the Child that she, as OCL Clinician, was also an employee of the CAST, but told the Child that she is a social worker there to speak with the Child about his views and preferences; and,
f) she had provided her resume to OCL legal counsel prior to the swearing of her second affidavit in this proceeding.
30The OCL Clinician confirmed that she had sworn two affidavits in this matter, dated September 2, 2025, and October 16, 2025. The OCL Clinician acknowledged that she swore in both affidavits the following about her experience:
I am a member of the clinical parent of the Office of the Children’s Lawyer (“OCL”) and have been for eleven years, since 2014. I have a Masters in Social Work , and I am a member in good standing of the College of Social Workers. As a clinical panel member of the OCL I assist counsel in meeting with children and providing evidence of their views and preferences to the court. I also conduct investigations and write reports under Section 112 of the Courts of Justice Act and prepare Voice of the Child Reports.
31During the Father’s lawyer’s cross-examination, the OCL Clinician was asked whether she thought her affidavit should state that she works for the CAST, and the OCL Clinician stated that she “didn’t feel that it was necessary”.
32During re-examination, the OCL lawyer asked her if she has access on CPIN to the files of other welfare agencies. The OCL Clinician acknowledged there are some. The OCL lawyer also asked whether, in her capacity as an OCL Clinician she could be assigned to a file where the opposing party was a different agency, and she could potentially have access to their records through CPIN. The OCL Clinician acknowledged that she could have access to any children’s aid society files as long as they were on CPIN.
CAST COUNSEL PROVIDING QUESTIONS TO OCL COUNSEL
33Following the OCL Lawyer’s re-examination of the OCL Clinician, Mother’s counsel brought to the Court’s attention that the CAST counsel had provided to the OCL counsel, the re-examination questions to ask the OCL Clinician.
34CAST counsel admitted that she had provided these questions to OCL counsel at the counsel table for the re-examination of the OCL Clinician.
ISSUES
35The issue for the Court to decide is whether the OCL Clinician’s evidence is admissible.
LAW
36The OCL seeks to admit the evidence from the OCL Clinician as representing the views and wishes of the Child.
37The OCL bears the burden of demonstrating on a balance of probabilities that necessity and reliability have been established: R. v. Khelawon, [2006] S.C.R. 787.
38Child hearsay can be admitted as an exception to the hearsay rule, using the principled approach of establishing necessity and reliability as set out in R. v. Khan, 1990 CanLII 77 (SCC), [1990] 2 S.C.R. 531.
The Importance of Hearing Children’s Views and Wishes
39For decades, there has been near worldwide consensus about the importance of children expressing their views and ensuring that those views are given due weight in proceedings that impact their lives. The usual starting point for discussions about a child’s right to representation is the United Nations Convention on the Rights of the Child (“UNCRC”), adopted by the United Nations in 1989, which enshrines the child’s right to be heard and the requirement that the child’s views are to be given due weight in all decisions impacting the child.
40On May 28, 1990, Canada became a signatory to the UNCRC and after all the provinces and territories confirmed their support, Canada ratified the UNCRC on December 13, 1991. In ratifying the UNCRC, Canada made a commitment to protect and fulfil children’s rights as expressed in the UNCRC.
41Article 12 of the UNCRC gives a child the right to be heard, and the right to have a child’s views given due weight in all matters affecting that child.
42In G. (B.J.) v. G. (D.L.), 2010 YKSC 44, Justice Martinson carefully reviewed children’s legal rights to be heard in a Yukon family law case. Justice Martinson identified that pursuant to both UNCRC and Canada’s own domestic laws, “all children in Canada have legal rights to be heard in all matters affecting them.”
43Children can participate in child protection proceedings in many different ways: directly if the child provides testimony or submits a written statement, or indirectly through the testimony of others, a report prepared by an expert on the child’s views, or through representation by an advocate or trained professional.
44At paragraphs 50-53, Justice Martinson discusses the various ways that the Child’s Voice can come before the court:
There are many different ways in which children`s views can be presented to the Court. The evidence can be presented by or through a neutral third party; this type of participation is generally ordered by the Court. That person is often a psychologist, psychiatrist or social worker. For example, it may be done by way of a comprehensive assessment, or a “views of the child” report. Specially trained lawyers can prepare and present the views of a child. Children can meet with a judge in what is referred to as a judicial interview.
Evidence can be presented about children’s views by either parent, or by a lawyer or other representative of the child. That evidence may be in the form of an affidavit of the child, “in court” testimony of the child, letters written by the child, audio tapes or videos of the child, evidence of the parent or another witness as to what the child has said to the person about his or her wishes, or an expert report presented on behalf of one parent.
45The CYFSA preamble encompasses the intent and spirit of Katelynn’s Principle and acknowledges that children are individuals with rights to be respected and voices to be heard.
46Subsection 74(3)(a) of the CYFSA states:
Where a person is directed in this Part to make an order or determination in the best interests of a child, the person shall,
(a) consider the child’s views and wishes, given due weight in accordance with the child’s age and maturity, unless they cannot be ascertained;
Reliability of the OCL Clinician’s Evidence
47In the unique circumstance of this case, the Court is addressing threshold reliability prior to necessity.
48In determining the issue of reliability, the legal test for the Court to apply at a voir dire involving child statements is whether the circumstances surrounding the statements achieve threshold reliability – not whether the statements are ultimately reliable: Children’s Aid Society of Toronto v. G.S., 2018 ONCJ 124 at paragraph 12.
49In R. v. Khelawon, 2006 SCC 57 at paragraphs 61-63, Justice Charron, writing for the Supreme Court of Canada, held that the reliability requirement will generally be met in one of two ways:
that there is no real concern about whether the statement is true or not because of the circumstance in which it came about; or
that no real concern arises from the fact that the statement is presented in a hearsay form because, in the circumstances, its truth and accuracy can nonetheless be sufficiently tested by means other than contemporaneous cross-examination.
50In R. v. Bradshaw, 2017 SCC 35, the Supreme Court of Canada re-stated the hearsay test set out in R. v. Khelawon. In Children’s Aid Society of Toronto v. G.S., 2018 ONCJ 124 at paragraph 16, Justice Sherr helpful summarized the statements in R. v. Bradshaw that are pertinent to the hearsay analysis, as follows:
i. The presumptive inadmissibility of hearsay may be overcome where its proponent establishes on a balance of probabilities that what is proposed for admission falls within a categorical exception, or satisfies the twin criteria of necessity and threshold reliability under the principled approach. – Bradshaw at pars. 22-23.
ii. In determining threshold reliability, the trier of fact must identify the specific hearsay dangers inherent in the out-of-court declaration. The trier of fact must then identify the means by which these dangers can be overcome. These dangers arise notably due to the absence of contemporaneous cross-examination of the hearsay declarant before the trier of fact (Khelawon, at paras. 35 and 48). The dangers relate to the difficulties of assessing the declarant’s perception, memory, narration, or sincerity, and should be defined with precision to permit a realistic evaluation of whether they have been overcome. – Bradshaw at para. 26.
iii. The hearsay dangers can be overcome, and threshold reliability can be established by showing that (1) there are adequate substitutes for testing truth and accuracy (procedural reliability) or (2) there are sufficient circumstantial or evidentiary guarantees that the statement is inherently trustworthy (substantive reliability) (Khelawon, at paras. 61-63; Youvarajah, at para. 30) – Bradshaw at para. 27.
iv. Procedural reliability is established when “there are adequate substitutes for testing the evidence”, given that the declarant has not “state[d] the evidence in court, under oath, and under the scrutiny of contemporaneous cross-examination” (Khelawon, at para. 63). These substitutes must provide a satisfactory basis for the trier of fact to rationally evaluate the truth and accuracy of the hearsay statement (Khelawon, at para. 76; Hawkins, at para. 75; Youvarajah, at para. 36).
v. A hearsay statement is also admissible if substantive reliability is established, that is, if the statement is inherently trustworthy (Youvarajah, at para. 30; R. v. Smith, 1992 CanLII 79 (SCC), [1992] 2 S.C.R. 915, at p. 929). To determine whether the statement is inherently trustworthy, the trial judge can consider the circumstances in which it was made and evidence (if any) that corroborates or conflicts with the statement (Khelawon, at paras. 4, 62 and 94-100; R. v. Blackman, 2008 SCC 37, [2008] 2 S.C.R. 298, at para. 55). – Bradshaw at para. 30.
vi. The two approaches to establishing threshold reliability may work in tandem. Procedural reliability and substantive reliability are not mutually exclusive (Khelawon, at para. 65) and “factors relevant to one can complement the other”. – Bradshaw at para. 32.
vii. The distinction between threshold and ultimate reliability, while “a source of confusion”, is crucial (Khelawon, at para. 50). Threshold reliability concerns admissibility, whereas ultimate reliability concerns reliance (Khelawon, at para. 3). – Bradshaw at para. 39.
viii. In short, in the hearsay context, the difference between threshold and ultimate reliability is qualitative, and not a matter of degree, because the trial judge’s inquiry serves a distinct purpose. In assessing substantive reliability, the trial judge does not usurp the trier of fact’s role. Only the trier of fact assesses whether the hearsay statement should ultimately be relied on and its probative value. – Bradshaw at para. 41.
51In the context of child protection proceedings, the court must be satisfied that the statements have been accurately and objectively reported, and, secondly, there is an absence of those factors which would undermine the reliability of the child’s statement. The court should inquire into the circumstances surrounding the making of the statement to satisfy itself that the child had not been manipulated, coerced or pressured into making such a statement: Children’s Aid Society of Metropolitan Toronto v. M. (R.), [1992] O.J. No. 1097 (Ont. Prov. Div.), as cited in Children's Aid Society of Ottawa-Carleton v. L.L., 2001 CanLII 28153 at paragraph 23.
52The Court of Appeal for Ontario described the duties of the OCL to child clients as requiring undivided loyalty, good faith and attention to the child’s interest, the exclusion of other interests, including the interests of the child’s parents, the interests of the Crown and the interests of the Ministry of the Attorney General: Ontario (Children's Lawyer) v. Ontario (Information and Privacy Commissioner), 2018 ONCA 559 at paragraph 69.
53In Jewish Family and Child Services of Greater Toronto v. K. (J.). [2014] O.J. No. 6618, 2014 ONCJ 792 (Ont. C.J.) at paragraph 53, Justice Jones noting the important elements of counsel’s role including independence, neutrality and loyalty.
54In Family and Children’s Services v. N. (K.)., 2017 ONCJ 202 at para. 21, Justice Baker identified the various competing interests in child protection proceedings as follows:
…. both the parent and the Society are acting under somewhat different imperatives. The parent is likely to present evidence that furthers their position and not to present evidence that does not. The Society, of course, has an obligation as an institutional litigant and agency of the State to present all evidence whether it favours its case or not.
But the Society has many different interests at play in dealing with any one case. It is, after all, a public agency answerable to government oversight. In many ways it may also be said to be answerable to the community that it serves. It has financial limitations that may cause tension in allocating resources.
The OCL, however, has only one mission: to protect the child’s interests.
55In M. (D.) v. Children’s Aid Society of Ottawa, 2021 ONSC 8360 at para. 24 (Ont. Div. Ct.), Justice Perell considering the Strobridge decision on the issue of the appropriate role of counsel and noted that that the “independent role of the Office of the Children’s Lawyer is critical, given the statutory requirement for the judge to consider the views and wishes of the children whenever the judge must consider the best interests of the child.”
56Children in child protection proceedings are meant to have independent representation before the court. There must be no blurred lines between the important role of the OCL, and the role of the CAST.
57The court should have confidence in the independent nature of the Child’s representation, as well as the absence of suggestion or manipulations.
58Ultimately, the court is concerned about the conflicting interests, and circumstances under which this evidence was created and tendered through this witness. With respect to the hearsay dangers specifically, the concern is the ability to assess the Child’s perception, memory, narration and sincerity, as well as the risk of inaccuracy. There is the possibility that the OCL Clinician as recorder of the statements had the ability to influence the statements, which increases the hearsay dangers.
59The Court finds that the OCL Clinician’s evidence is not sufficiently reliable to meet the threshold reliability test because of the conflicting interests, and circumstances in which the evidence came about, specifically the following:
a) the OCL Clinician is a full-time employee of the CAST;
b) prior to the trial, the OCL Clinician had sworn two affidavits in this proceeding that outline her work experience but fail to disclose her current employment with the CAST, despite being her full-time job for decades;
c) prior to the trial, the OCL had been asked to provide a curriculum vitae for the OCL Clinician but failed or refused to do so;
d) the OCL Clinician’s testimony in this voir dire was not credible or reliable, and her conduct displayed a concerning lack of understanding of the need to avoid conflicts of interest, including,
i. the OCL Clinician denied she had access to CPIN files that she was not assigned. The OCL Clinician admitted in cross-examination that she does have access but would not access files that were not assigned to her. However, during re-examination, the OCL Clinician admitted that she does have access to CAST files, and potentially also access to other children’s aid societies’ files,
ii. the OCL Clinician stated that she would not have had difficulty taking a position that was different from the CAST position because she had no idea what the CAST position was, but she previously testified she had reviewed the pleadings and CAST affidavit in the matter,
iii. the OCL Clinician denied having met the Current Family Services worker, which was inconsistent with the credible evidence on this matter of the Current Family Services Worker,
iv. the OCL Clinician appeared to view the work of the CAST and the OCL as “complementary to one another”, and
v. the OCL Clinician did not disclose whether she knew the intake worker on the file, despite being an intake worker herself;
e) neither the OCL nor the CAST took any steps to ensure an ethical wall or any restrictions whatsoever on the OCL Clinician’s access to CPIN, information, or CAST workers involved in this matter;
f) the CAST workers in this file are co-workers of the OCL Clinician;
g) the Child was not advised of the OCL Clinician’s employment with the CAST; and
h) the conduct of the OCL’s legal counsel and the CAST’s legal counsel during the voir dire, suggested joint efforts to unfairly support the CAST’s position in this proceeding.
Necessity of the OCL Clinician’s Evidence
60There is no presumption of necessity where the out-of-court statement is made by a child: Valoris v. J.W., C.R. Muskeg Lake Cree Nation, 2022 ONSC 349 at paragraph 22.
61In family cases involving child hearsay, the necessity requirement takes into account what is reasonably necessary and considers the harm to a child of having to testify in court: Y.M.S. v. R.O.S., 2021 ONSC 6684 at paragraph 33; Children's Aid Society of Ottawa-Carleton v. L.L., 2001 CanLII 28153 at paragraph 6.
62In a child protection proceeding where the focus is on the best interests, protection and wellbeing of children, the dual criteria of necessity and reliability should be interpreted in a way that is sensitive to the child’s needs, particularly when considering whether it is reasonably necessary for a child to testify: Children's Aid Society of Ottawa-Carleton v. L.L., 2001 CanLII 28153 at paragraph 6.
63The nature of the evidence required on the issue of necessity should depend upon the age of the child, nature of the statements and the circumstances of the case: Children's Aid Society of Ottawa-Carleton v. L.L., 2001 CanLII 28153 at paragraph 10.
64In the course of the trial, the Court was told that a witness, identified as the Child’s therapist, had consent from the Child to provide evidence of the child’s views and wishes. There are also other sources of evidence of the Child’s views and wishes that could assist the court, including the evidence of the CAST workers, the Kith Caregivers, and the parents.
65Given the nature of the statements, other available sources of more reliable evidence of the Child’s views and wishes, in the circumstances of this case, the Court does not find the OCL Clinician’s evidence is necessary.
CONCLUSION
66The evidence of the OCL Clinician is not admitted.
67The Respondents’ costs of the voir dire hearing are reserved.
UNFAIR CONDUCT BY COUNSEL DURING THE VOIR DIRE
68Children, their parents, kin and kith, as well as the court must have confidence in the independence and integrity of institutions in Ontario responsible for representing children’s interests, and the protection of children.
69During the voir dire hearing, the CAST’s legal counsel admitted to providing to the OCL legal counsel, the re-examination questions asked of the OCL Clinician.
70There are strict parameters about when and why re-examination will be permissible: Toronto Transit Commission v. Zeng, 2018 ONCJ 261 at paragraph 29.
71The purpose of re-examination is largely rehabilitative and explanatory. The witness is afforded the opportunity, under questioning by the examiner who called the witness in the first place, to explain, clarify or qualify answers given in cross-examination that are considered damaging to the examiner’s case: R. v. Candir, 2009 ONCA 915 at paragraph 148.
72Re-examination is not an opportunity for a separate party, aligned in interest, to assist in rehabilitating another party’s witness, particularly when the two aligned parties are in a voir dire to determine a potential conflict of interest and admissibility of evidence.
ADDENDUM
73Following the Court’s decision, the following morning, counsel for the OCL indicated that internal changes are being made at the OCL office to address the issues raised in this voir dire. A similar acknowledgment was not made by the CAST. The court agrees with the OCL that genuine changes are needed to safeguard the interests of children and to ensure the effective and independent representation of children in child protection proceedings.
Justice J. Harris