This is a mandatory 90-day detention review under s. 525 of the Criminal Code.

The court addresses the onus at such reviews, distinguishing between cases where an initial bail hearing was held (no onus on either party) and where none was held (onus reverts to Crown/accused as per s. 515).

The court also clarifies the appropriate procedures and scope of s. 525 reviews, emphasizing they are not de novo bail hearings and that the Palmer/St-Cloud due diligence and relevance criteria for new evidence still apply.

The applicant sought release based on a new surety plan, but the court found it did not constitute a material change in circumstances and dismissed the application, finding continued detention justified.