DISCIPLINE COMMITTEE OF THE ROYAL COLLEGE OF DENTAL SURGEONS OF ONTARIO
Date: 2026-05-08 File No.: 23-0759
BETWEEN:
Royal College of Dental Surgeons of Ontario
-and-
Michelle Gauthier Registration No: 72855
FINDING AND PENALTY REASONS
RESTRICTION ON PUBLICATION
In the matter of the Royal College of Dental Surgeons of Ontario and Dr. Gauthier the Discipline Panel ordered, under ss 45(3) of the Health Professions Procedural Code, that no person shall publish or broadcast the identity of any patients of the Registrant, or any information that could disclose the identity of any patients who are named in the Notice of Hearing and/or any of the exhibits in this matter.
PANEL MEMBERS:
Judy Welikovitch, Public Member (Chair) Andre Theoret, Professional Member Peter Delean, Professional Member Brian Smith, Public Member Andrea Gonsalves, Subject Matter Expert
APPEARANCES:
Ahmad Mozaffari, for the College Stephanie DiGiuseppe and Colin Wickham, for Dr. Michelle Gauthier
Heard: April 9, 2026, by videoconference
DECISION AND REASONS
This matter came on for a hearing before a panel of the Discipline Committee of the Royal College of Dental Surgeons of Ontario (the “Panel”) in Toronto on April 9, 2026. This matter was heard by way of videoconference.
Prior to the hearing date, the Registrant, Dr. Michelle Gauthier, brought two motions in respect of this matter.
The first motion was to have this matter heard on an in-person basis. This motion was dismissed on February 6, 2024 by the Chair after reviewing the applicable legislation, policy and Rules of the Discipline Committee, as well as the written submissions of the parties.
The second interlocutory motion was to exclude certain evidence from the hearing of this matter. The motion was heard over a period of two (2) days by a panel of the Discipline Committee. That panel dismissed the motion and issued a written Endorsement on October 2, 2025.
At the commencement of the hearing, the Chair confirmed that the publication ban previously ordered on July 3 and 4, 2025, would apply throughout the proceeding in this matter, including to this merits hearing.
THE ALLEGATIONS
- The College’s allegations of professional misconduct against the Registrant, Dr. Michelle Gauthier, are set forth in Notice of Hearing No. 23-0759 (the “NOH”). It contains the following three separate allegations:
(a) The College alleged that Dr. Gauthier sexually abused a patient, namely Patient A, which is professional misconduct as provided by s. 51(1)(b.1) of the Health Professions Procedural Code (the “Code”), being schedule 2 of the Regulated Health Professions Act, 1991, S.O. 1991, c 18 (the “RHPA”). More particularly, the College alleged that:
i. Dr. Gauthier engaged in a concurrent sexual and treating relationship with Patient A commencing on or about November 6, 2020;
ii. Dr. Gauthier provided treatment to Patient A on at least six (6) occasions in or about 2020 and 2021 while at the same time engaging in a sexual relationship that included sexual intercourse and/or other forms of sexual relations with him, and behaviour and or remarks of a sexual nature; and
iii. Dr. Gauthier also sent electronic messages of a sexual nature to Patient A while he was her patient;
(b) The College alleged that Dr. Gauthier committed acts of professional misconduct as provided by s. 51(1)(c) of the Code in that during the years 2020 and 2021, the Registrant abused Patient A, contrary to paragraph 8 of section 2 of Ontario Regulation 853/93 (the “Professional Misconduct Regulation”). More particularly, the College alleged that:
i. Dr. Gauthier engaged in a concurrent sexual and treating relationship with Patient A commencing on or about November 6, 2020;
ii. While Patient A was her patient, Dr. Gauthier engaged in sexual intercourse and other forms of sexual relations with Patient A, and in touching of a sexual nature and/or behaviour or remarks of a sexual nature; and
iii. Dr. Gauthier also sent electronic messages of a sexual nature to Patient A while he was her patient;
(c) The College alleged that Dr. Gauthier committed an act or acts of professional misconduct as provided by s. 51(1)(c) of the Code in that during the years 2020 and/or 2021, she engaged in conduct or performed an act or acts that, having regard to all the circumstances, would reasonably be regarded by registrants of the profession as disgraceful, dishonourable, unprofessional or unethical relative to Patient A, contrary to paragraph 59 of section 2 of the Professional Misconduct Regulation. More particularly, the College alleged that:
i. In or around 2020 and 2021, Dr. Gauthier breached appropriate dentist-patient boundaries with Patient A by engaging in an intimate personal relationship with him while he was her patient that included but was not limited to purchasing gifts for Patient A, providing financial support to Patient A, and travelling for personal purposes with Patient A on at least two (2) occasions.
THE REGISTRANT’S PLEA
- Dr. Gauthier denied each of the allegations against her. Her counsel advised the Panel that although Dr. Gauthier denied the allegations, she would not be calling any evidence and did not intend to cross-examine Patient A on an affidavit he provided that was filed in evidence by the College.
THE EVIDENCE
The College relied solely upon the Affidavit of Patient A (the “Affidavit”) to prove its case against Dr. Gauthier. Dr. Gauthier did not cross-examine Patient A on his affidavit. His evidence was thus uncontroverted.
The evidence set out in the Affidavit established the following:
a. Patient A first met Dr. Gauthier when she contacted him in connection with a business that he was operating at the time. Patient A had not previously met or communicated with the Registrant prior to her reaching out to him;
b. Patient A first met Dr. Gauthier on or about October 21, 2020 and shortly thereafter, he attended an appointment with her at her dental office, Lynhurst Dental in St. Thomas, Ontario (the “Clinic”);
c. Patient A and the Registrant first began an intimate relationship shortly after meeting. They had sexual intercourse for the first time on or about October 31, 2020. The intimate relationship between Patient A and Dr. Gauthier continued throughout 2021;
d. Patient A first received dental treatment from Dr. Gauthier on November 6, 2020, and continued to receive dental treatment from the Registrant over the next four (4) months. He attended appointments with Dr. Gauthier on November 17, 2020, February 4, 10 and 22, 2021 and March 1, 2021;
e. Over the course of their relationship, Dr. Gauthier and Patient A spent time at her home; they attended events together in St. Thomas; and Patient A would often drive to the Registrant’s home to go on walks with her;
f. Patient A also went on personal trips with Dr. Gauthier, including travelling to Toronto in November 2020 where they stayed in a hotel paid for by the Registrant. They also travelled together during the summer of 2021;
g. Patient A and Dr. Gauthier exchanged many electronic messages throughout the course of their relationship, many of which were sexual in nature. They communicated primarily over Instagram, but they also communicated on Facebook Messenger, and via text and email. Copies of some of the messages exchanged by the Registrant and Patient A were attached as an exhibit to his Affidavit and were thus available for review by the Panel;
h. In addition to the relationship as described above, Dr. Gauthier also provided financial assistance to Patient A over the course of their relationship: she helped him purchase two vehicles, both of which were placed in the names of both the Registrant and Patient A. In or around the Fall, 2021, Patient A and Dr. Gauthier became involved in a dispute about monies owing in relation to one of the vehicles;
i. In addition to helping him finance the two vehicles, Dr. Gauthier would often give Patient A gifts, including shoes and clothing. Patient A stated that Dr. Gauthier would often make him feel guilty about the fact that she had provided him with financial assistance; and
j. Patient A made a complaint to the College about Dr. Gauthier in January 2023.
After hearing the evidence called by the College, Dr. Gauthier waived her right to call additional evidence, she waived her right to cross-examine Patient A on his affidavit, and she waived her right to challenge the credibility of the affiant, Patient A. The Registrant’s counsel also conceded that the evidence tendered by the College was sufficient to meet the College’s burden of proof.
The College submitted that it had met its burden and had proved that Dr. Gauthier engaged in the professional misconduct as described above. It submitted that the evidence of Patient A was uncontroverted and that no questions about his credibility had been raised. It directed the Panel’s attention to the definition of “sexual abuse of a patient” contained in subsection 1(3) of the Code to establish that the conduct described by Patient A amounted to sexual abuse. The College also directed the attention of the Panel to other decisions of this Discipline Committee which involved allegations of sexual abuse and abuse of a patient (RCDSO v Kochman, 2025 ONRCDSO 5; and RCDSO v Rondeau, 2024 ONRCDSO 2). The College submitted that Dr. Gauthier’s conduct would reasonably be considered by registrants of the College as disgraceful, dishonourable, unprofessional and unethical.
DECISION
The Panel deliberated and considered the evidence before it, and the submissions of the parties.
The Panel rendered an oral decision on April 9, 2026, finding that Dr. Gauthier committed acts of professional misconduct as alleged in the Notice of Hearing, and contrary to sections 51(1)(b.1) and 51(1)(c) pf the Code and subsections 2(8) and 2(59) of the Professional Misconduct Regulation.
More particularly, the Panel found that the College met its burden: it proved, on a balance of probabilities, that Dr. Gauthier engaged in sexual abuse of her patient, that she abused Patient A, and that her conduct would reasonably be considered by registrants of the dental profession as disgraceful, dishonourable, unprofessional and unethical.
REASONS FOR DECISION
- Dr. Gauthier denied the allegations as set forth above; however, she did not contest the facts set out in the Affidavit of Patient A, nor did she challenge his credibility. The Panel found that the evidence contained in Patient A’s Affidavit proves professional misconduct under the heads of misconduct as set out above.
Sexual abuse of a patient – Subsection 51(1)(b.1) of the Code
Pursuant to subsection 51(1)(b.1) of the Code, a panel must find that a registrant has committed an act of professional misconduct if that registrant has sexually abused a patient.
Put more plainly, the RHPA and Code contain an absolute prohibition on sexual abuse of a patient, which is defined in subsection 1(3) of the Code to mean “(a) sexual intercourse or other forms of physical sexual relations between the [registrant] and the patient”; (b) touching of a sexual nature of a patient by a registrant; or (c) behaviour or remarks of a sexual nature by the registrant towards a patient.
Patient A stated under oath that he first met Dr. Gauthier on October 21, 2020, and that they commenced a personal relationship that included sexual intercourse beginning on October 31, 2020.
Concurrently, Patient A began receiving dental treatment from Dr. Gauthier beginning on November 6, 2020. He received dental treatment from Dr. Gauthier at six (6) appointments ending on March 1, 2021. He stated that he received treatment from Dr. Gauthier at the Clinic “…when we were in an intimate relationship involving sexual intercourse.” This evidence was uncontroverted.
In addition, the Panel reviewed evidence of electronic communications between Patient A and Dr. Gauthier that included remarks of a sexual nature. Again, this evidence was uncontroverted.
The Panel was satisfied that the College met its burden of proving, on a balance of probabilities, that Dr. Gauthier engaged in sexual intercourse with Patient A, touching of a sexual nature of Patient A, and behaviour and remarks of a sexual nature towards Patient A, all concurrent with a treating relationship with Patient A. She therefore sexually abused her patient and engaged in professional misconduct contrary to section 51(1)(b.1) of the Code.
Abuse of a patient – section 51(1)(c) of the Code
Pursuant to subsection 51(1)(c) of the Code, a panel must find that a registrant has committed professional misconduct if that registrant has committed an act of professional misconduct as defined in the Professional Misconduct Regulation.
The Professional Misconduct Regulation provides, at subsection 2(8), it is an act of professional misconduct for a registrant to abuse a patient.
Patient A gave evidence that Dr. Gauthier engaged in a concurrent treating and sexual relationship with him during 2020 and 2021, as described above.
Patient A further stated under oath that Dr. Gauthier helped him finance the purchase of two vehicles, and that she would often give him gifts including shoes and clothing. Dr. Gauthier and Patient A also travelled together for personal reasons on at least two occasions – travel paid for by Dr. Gauthier. Patient A stated that Dr. Gauthier would often make him feel guilty about the fact that she had provided him with financial assistance.
There is an inherent power imbalance between a dentist and their patient such that the dentist must maintain strict boundaries to ensure the patient is protected from an abuse of power. By engaging in a concurrent treating and sexual relationship with Patient A, and providing financial assistance to Patient A, the Registrant breached those boundaries and abused her patient. Based upon the uncontroverted evidence presented by the College, the Panel found that the College met its burden of proving, on a balance of probabilities, that Dr. Gauthier engaged in abuse of Patient A, contrary to subsection 51(1)(c) of the Code and subsection 2(8) of the Professional Misconduct Regulation.
Disgraceful, Dishonourable, Unprofessional or Unethical Conduct – s. 2(59) of the Professional Misconduct Regulation
Dr. Gauthier denied that she had engaged in conduct that would reasonably be regarded by members of the College as disgraceful, dishonourable, unprofessional or unethical.
The evidence before the Panel established that Dr. Gauthier sexually abused Patient A as defined in subsection 1(3) of the Code and that she abused Patient A as proscribed by the Professional Misconduct Regulation.
Dr. Gauthier’s conduct included having sexual intercourse with Patient A, exchanging sexually explicit electronic messages with him, and travelling with him for personal reasons at her expense. She bought him gifts and she helped him financially in purchasing two vehicles. He stated that she made him feel guilty about the fact that she had provided him with financial assistance. The Panel found that these behaviours violated the boundaries of the dentist-patient relationship in significant ways.
Maintaining professional boundaries both respects patients and helps ensure the provision of safe and effective care, and it upholds the public’s trust in dentistry1. Dr. Gauthier’s conduct constituted serious breaches of the dentist-patient boundary that a registrant is expected to maintain. The Registrant’s misconduct was not a single isolated breach but rather a course of conduct that continued over months.
The Panel thus found that Dr. Gauthier’s conduct in respect of Patient A would reasonably be considered by registrants of the profession to be disgraceful, dishounourable, unprofessional and unethical.
In reaching its conclusions that Dr. Gauthier sexually abused Patient A, that she abused Patient A, and that she engaged in conduct that would reasonably be considered to be disgraceful, dishonourable, unprofessional and unethical, the Panel also reviewed the decisions of panels of the College’s Discipline Committee in Kochman and Rondeau (cited above). In both cases, the dentist was found to have engaged in sexual abuse of a patient, abuse of a patient, and to have engaged in conduct that registrants of the profession would reasonably consider to be disgraceful, dishonourable, unprofessional or unethical.
PENALTY SUBMISSIONS
- After it announced its decision on the misconduct allegations, the parties provided the Panel with a Joint Submission on Order (“JSO”). In the JSO, the parties jointly submitted that the Panel should impose the following order on Dr. Gauthier:
(a) Requiring Dr. Gauthier to appear before the Panel to be reprimanded within ninety (90) days of this Order becoming final or on a date fixed by the Registrar;
(b) Directing the Registrar to revoke her certificate of registration, effective immediately;
(c) Requiring Dr. Gauthier to reimburse the College for funding provided to Patient A under the program required under section 85.7 of the Code;
(d) Requiring Dr. Gauthier to post security in the amount of $17,370 to guarantee payments of any amount she is required to pay under paragraph (c) above; and
(e) Requiring Dr. Gauthier to pay costs to the College in the amount of $50,000 in respect of this discipline hearing within thirty (30) days of the date the Panel’s Order becomes final.
Test in Anthony-Cook and Bradley
The College initially submitted that the Panel should not depart from the parties’ joint proposal on penalty unless the proposed penalty would bring the administration of justice into disrepute or is otherwise contrary to the public interest.” This test, set out by the Supreme Court of Canada in R v Anthony-Cook, 2 has been repeatedly adopted in the administrative law context, notably in Bradley, 3 a decision of the Ontario Superior Court (Divisional Court).
It is unquestionable that Anthony-Cook establishes a very high bar for a panel to meet should it wish to depart from the parties’ joint proposal on penalty and costs.
This case, however, differs from Anthony-Cook in a significant way. In that case, the Court emphasized the importance of joint submissions on sentence where the accused pleads guilty or, in the College discipline context, where the registrant admits the allegations of professional misconduct.4
The Supreme Court explained that the stringent test it adopted was necessary, to a large extent, because of the quid pro quo provided by accused persons in giving up their right to a trial and pleading guilty in exchange for a joint submission; that in exchange for a plea of guilty, accused persons require a high degree of certainty that the joint submission agreed upon will be respected.5
More recently, in R v Wesley,6 the Ontario Court of Appeal distinguished cases where the accused pleads guilty in exchange for a joint recommendation as to penalty from those cases where an agreement on sentence is reached following a trial at which the accused pled not guilty. The Court said that “no similar quid pro quo exists in cases involving a joint recommendation following a trial, even in a case …where the Crown and the defence engage in negotiations that lead to the joint recommendation. While both the Crown and the appellant arguably gave up the right to seek either a higher or lower parole ineligibility period at a contested sentencing hearing, such compromises do not approach the quid pro quo provided by an accused in foregoing the right to a trial.”7 (Emphasis added)
When the Panel questioned College counsel about the applicability of the Anthony-Cook test in light of Dr. Gauthier’s denial of the allegations, the College referred the Panel to Wesley and acknowledged that the Anthony-Cook test does not apply in this case. However, counsel for both parties urged the Panel to accept the joint submission because (1) paragraphs (a) and (b) of the JSO are mandatory under the Code, (2) the penalty is appropriate having regard to all the circumstances of this case, and (3) the parties’ agreement should be given considerable weight.
Dr. Gauthier’s counsel made extensive submissions regarding the circumstances that contributed to her acts of professional misconduct.
PENALTY DECISION
The Panel deliberated and considered the JSO and the submissions of the parties.
The Panel agreed with the parties that the high bar set in Anthony-Cook does not apply in this case because Dr. Gauthier denied the allegations. The public interest test to depart from a joint submission applies in cases where the registrant has admitted the allegations and has entered a plea based on an agreed statement of facts.
Nevertheless, the Panel found that the penalty terms agreed to by the parties in the JSO are reasonable in the overall circumstances of the case. It made an order in accordance with its provisions, as follows:
(a) Requiring the Registrant to appear before the Panel to be reprimanded within ninety (90) days of this Order becoming final or on a date fixed by the Registrar;
(b) Directing the Registrar to revoke the Registrant’s certificate of registration, effective immediately;
(c) Requiring the Registrant to reimburse the College for funding provided to the Complainant under the program required under section 85.7 of the Code;
(d) Requiring the Registrant to post security in the amount of $17,370 to guarantee payments of any amount she is required to pay under paragraph (c) above; and
(e) Requiring the Registrant to pay costs to the College in the amount of $50,000 in respect of this discipline hearing, within 30 days of the date this Order becomes final.
REASONS FOR PENALTY DECISION
Although, for the reasons set forth above, this Panel is not bound to adhere to the terms and conditions of the JSO, it did consider the recommendation in the full context of the proceeding.
The Panel also considered the basic principles relating to the imposition of penalties. Those principles include that: (a) the goal of a penalty is to protect the public from dentists who have committed professional misconduct and to maintain public confidence in the profession and in its ability to self-regulate; (b) a penalty must serve as a measure of general deterrence, in that it sends a message to all registrants of the dental profession that this type of conduct will not and cannot be tolerated; (c) it must also serve as a measure of specific deterrence with respect to the dentist concerned; (d) an appropriate penalty should also provide for remediation or rehabilitation of the dentist concerned, where possible and appropriate; and lastly, (e) the Panel must consider both mitigating and aggravating factors when assessing the appropriateness of the penalty in the circumstances.
Oral Reprimand to be Delivered in Person
Pursuant to subsection 51(5.1) of the Code, the Panel is required to deliver a reprimand to the Registrant upon a finding of sexual abuse by that Registrant.
Dr. Gauthier waived her right to appeal this decision and asked that the reprimand be read at the conclusion of the hearing. The Panel did so.
The reprimand delivered to the Registrant will have the following impact:
(a) It will have a general deterrent effect in that it is a public denunciation by the Panel of Dr. Gauthier’s conduct. This will send a clear message to members of the profession that this type of professional misconduct cannot and will not be tolerated;
(b) It will achieve the goals of transparency and public accountability, and it will strengthen public confidence in the profession’s ability to regulate itself and to hold dentists accountable for poor conduct or practice; and
(c) It will have a specific deterrent effect upon Dr. Gauthier, herself.
Revocation of Certificate of Registration
Pursuant to subsection 51(5.3) of the Code, the Panel is required to revoke the Registrant’s certificate of registration having made the finding that the Registrant committed an act of professional misconduct by sexually abusing a patient including having sexual intercourse with a patient. The Panel found, on a balance of probabilities, that Dr. Gauthier engaged in a sexual relationship with Patient A that included sexual intercourse.
Revocation of a dentist’s certificate of registration is the most severe penalty a Panel can impose. Revocation of Dr. Gauthier’s certificate is not only required by law, it is also appropriate in the circumstances of this case. Dr. Gauthier’s conduct fell well below the standard of professionalism that is expected of dentists. Moreover, the impugned conduct was not limited to a single occurrence. Rather, the sexual relationship between Dr. Gauthier and Patient A continued during 2020 and 2021. Dr. Gauthier crossed the dentist-patient boundary by engaging in a sexual relationship with Patient A, by supporting him financially, helping him to purchase two vehicles, by buying him gifts including clothing and shoes, and by going on personal trips with Patient A for which she paid. Dr. Gauthier put the reputation of the profession at risk, and she jeopardized the public’s confidence in the College’s ability to regulate the profession.
Only a penalty of revocation can appropriately deter the kind of misconduct that occurred here and maintain public confidence in the dentistry profession.
Funding for Therapy and Counselling – Code, Section 85.7
- Pursuant to section 85.7 of the Code, the College has established a program to fund therapy and counselling for persons who allege sexual abuse by a registrant. The Panel found that an order requiring Dr. Gauthier to reimburse the College for any funding provided to Patient A and requiring her post security in the amount of $17,370 to guarantee payment of any amount that she is required to pay under section 85.7 of the Code – is reasonable in the circumstances. In making this decision, the Panel considered the following factors:
(a) That the relationship between Dr. Gauthier and Patient A extended over a prolonged period beginning in October 2020;
(b) That Dr. Gauthier did not begin treating Patient A until November 6, 2020, after their personal relationship had begun;
(c) At Paragraph 12 of his Affidavit, Patient A stated that he felt that Dr. Gauthier would often make him “feel guilty” about the fact that she had provided him with financial assistance.
Registrant Required to Pay College Costs
Section 53.1 of the Code provides, in part, that in an appropriate case, a panel may make an order requiring the registrant whom the panel found has committed an act or acts of professional misconduct to pay all or part of the College’s legal costs and expenses incurred in conducting the hearing.
The Panel agreed with the parties’ joint submission that an order for costs in the amount of $50,000 is appropriate in this case.
Over the course of these proceedings, Dr. Gauthier brought a motion for an in-person hearing which was dismissed by the Chair. She also brought a motion to exclude certain evidence. This motion was dismissed by the Panel after a two-day hearing.
At the hearing on the merits, Dr. Gauthier did not admit the allegations against her and required the College to meet its burden of proof, which is her right. The Panel found that the College established that Dr. Gauthier committed the professional misconduct, as alleged.
In these circumstances, the Panel found that it was appropriate and reasonable that Dr. Gauthier pay $50,000 towards the College’s costs of the proceedings.
I, Judy Welikovitch, sign these Reasons for Decision as Chairperson of this Discipline Panel.
APPENDIX “A”
RCDSO v. Dr. Michelle Gauthier
Dr. Gauthier, as you know, this Discipline panel has ordered you be given an oral reprimand as part of the sanction imposed upon you. The reprimand should impress upon you the seriousness of your misconduct.
The fact that you have received this reprimand will be part of the public portion of the Register and, as such, part of your record with the College.
You will be given an opportunity to make a statement at the end of the reprimand if you wish.
The panel has found that you have engaged in multiple acts of professional misconduct. The misconduct related to sexual abuse of your patient including sexual intercourse, abuse of your patient and egregious boundary violations.
The cumulative effect of your conduct would reasonably be regarded by Registrants as disgraceful, dishonourable, unprofessional and unethical.
Your professional misconduct is a matter of profound concern. It is completely unacceptable to your fellow dentists and to the public. You have brought discredit to the entire profession and to yourself. Public confidence in this profession has been put in jeopardy.
Of special concern to us is the fact that the professional misconduct in which you engaged took place over an extended period of time. You sexually abused your patient, which is the most serious abuse of power and breach of trust in a dentist-patient relationship.
We have ordered the penalty of revocation, being the most significant penalty this Committee can impose. It is a mandatory consequence of your misconduct. Revocation is appropriate because your conduct represents a fundamental breach of trust. The order we have imposed is necessary to protect the public and to send a message to the profession that conduct of this nature will not be tolerated.
As I advised earlier, you will now be given an opportunity to make a comment if you wish to do so. This is not an opportunity for you to debate the merits or the correctness of the decisions we have made.
Do you have any questions or do you wish to make any comments?
(Hear the Registrant’s comments at this point)
Thank you for attending today. We are adjourned.
Footnotes
- RCDSO Standard of Practice: Prevention of Boundary Violations and Sexual Abuse; Principle 5, Page 3
- R v Anothony-Cook, 2016 SCC 43, [2016] 2SCR 204
- Bradley v Ontario College of Teachers, 2021 ONSC 2303
- Ibid, Para. 25
- R v Wesley, 2025 ONCA 51, 175 OR(3rd) 165, Para. 72
- Ibid
- Ibid, Para.76

