Application for review of refusal to disclose document dismissed; solicitor-client privilege upheld.
The applicant sought access to a pre-charge screening document under the Access to Information Act.
The Department of National Defence refused disclosure, citing solicitor-client privilege under section 23.
The applicant applied for a review, arguing the privilege did not extend to factual elements and had been waived during a meeting with the alleged victim.
The Federal Court dismissed the application, finding the document was fully protected by privilege, no waiver had occurred, and the Department's exercise of discretion to refuse disclosure was reasonable.