The applicant, charged with drug trafficking, brought an application for the disclosure of police disciplinary records relating to two officers involved in the investigation.
The court held that the disciplinary file of an officer who would not be called as a Crown witness was not first party disclosure and did not meet the 'likely relevant' threshold for third party records.
For the undercover officer who would testify, the court ordered the police to ascertain whether specific additional disciplinary records existed, but otherwise dismissed the application.
