A motion by the respondent mother for disclosure of all records relating to the child from the Children's Aid Society, the child's psychiatrist, a counselling agency, and the family doctor.
The applicant society initially opposed disclosure of third-party records without consent, but the court found that the mother was entitled to full disclosure of society records including third-party records in its possession.
The court also ordered disclosure of non-party records held by the psychiatrist, family doctor, and counselling agency, subject to privilege claims and restrictions on use.
The court granted the mother's motion with modifications, recognizing the paramount importance of disclosure in child protection proceedings while protecting the child's private therapeutic communications.