The applicant, charged with sexual offences against his grandchildren, brought a Rowbotham application seeking state-funded counsel.
The court dismissed the application, finding that the applicant failed to provide full and frank financial disclosure to establish indigence and had not made reasonable efforts to save funds for his defence.
Furthermore, the court held that the case was not sufficiently complex to require counsel for a fair trial, noting that the trial judge could appoint counsel to cross-examine the complainants under section 486.3(2) of the Criminal Code.
