The accused, charged with human trafficking and sexual services offences, brought a pre-trial motion for the disclosure of redacted portions of a complainant's police statement.
The Crown argued the redacted information, which related to an unrelated criminal investigation and the complainant's sexual history, was clearly irrelevant and raised privacy concerns.
The court applied the Stinchcombe framework, finding that the low threshold for relevance favoured disclosure and that the redacted portions were not clearly irrelevant to the defence.
The court also rejected the Crown's argument that the statement constituted a 'record' under section 278.1 of the Criminal Code, concluding it was subject to the common law first-party disclosure regime.
The application for disclosure was granted.
