Robert Ratcliffe

The applicant sought judicial review of decisions by the Information and Privacy Commissioner denying him access to certain government and police records related to his 1982 prosecution for fraud.

The applicant sought the records for use in a civil action for malicious prosecution.

The Divisional Court dismissed the application, finding that the Assistant Commissioners reasonably applied the statutory exemptions for advice to government and personal privacy under FIPPA and MFIPPA.

The court affirmed that the applicant's private interest in civil litigation did not constitute a compelling public interest sufficient to override the privacy exemptions.

The applicant sought judicial review of a decision by the Ontario Civilian Commission on Police Services, which confirmed the dismissal of his complaint against a police officer.

The complaint arose from an incident where police responded to a landlord-tenant dispute involving the applicant, who is elderly and disabled.

The Divisional Court applied the patent unreasonableness standard of review and found that the Commission's conclusion—that there was no reasonable basis in the evidence to proceed to a hearing for police misconduct—was not patently unreasonable.

The application for judicial review was dismissed.

The applicant sought judicial review of a decision by the Assistant Commissioner upholding the Ministry's refusal to disclose expense records and notebooks of the OPP security detail for former Premier Harris.

The Assistant Commissioner found that disclosing the records could reveal the size and pattern of the security detail, reasonably endangering the safety of the Premier and officers under s. 14(1)(e) of the Freedom of Information and Protection of Privacy Act.

The Divisional Court dismissed the application, holding that the Assistant Commissioner applied the correct test and reasonably concluded there was an evidentiary basis for the exemption.