Shawn Cléroux

The responding party filed an application for judicial review challenging the policies and procedures of the moving party police service, following an access to information request for police records.

The moving party brought a requisition under Rule 2.1.01 of the Rules of Civil Procedure to dismiss the application.

The court found the application was frivolous on its face because it sought to review an Information and Privacy Commissioner decision rather than a decision of the police service, and because unspecified policies and procedures cannot be judicially reviewed.

The request was granted and the application against the police service was dismissed.

The Information and Privacy Commissioner of Ontario (IPC) brought a motion to seal a portion of its record of proceedings in an application for judicial review.

The applicant sought judicial review of IPC decisions regarding redacted police records.

The IPC sought to file an unredacted 'private' record under seal to prevent the premature disclosure of the very information at issue in the judicial review.

The court granted the sealing order, finding it necessary to prevent a serious risk to the integrity of the judicial review process and noting that disclosure would render the application moot.