The accused applied for a bail review under s. 520 of the Criminal Code after being detained following a breach of recognizance.
The court accepted that a material change existed due to a revised release plan including strict house arrest, continuous supervision by sureties, and electronic monitoring.
While the court found the proposed plan addressed the secondary ground concerning risk of further offences, the tertiary ground remained decisive.
Given the extremely serious allegations involving kidnapping, violent assault, extortion, and impersonating a police officer, together with the strength of the Crown’s evidence and the accused’s prior breach of release conditions, detention was necessary to maintain public confidence in the administration of justice.
The accused failed to discharge the reverse onus required to justify release.