The applicant filed a complaint regarding police conduct during encampment clearings.
After the Toronto Police Service investigated and substantiated only one minor allegation, the applicant sought judicial review of the investigation's adequacy.
The Toronto Police Service brought a motion to quash the application.
The Divisional Court granted the motion, finding that the application was bound to fail because the applicant had not exhausted the mandatory administrative review process under section 71 of the Police Services Act, which requires seeking a review by the OIPRD before applying for judicial review.