The appellant wife appealed an interim order restraining her from sending scurrilous letters to third parties about her husband, and a sealing order.
The Divisional Court dismissed the appeal, finding that such letters can constitute harassment under section 46 of the Family Law Act.
The court held that while the order infringed the appellant's freedom of expression under section 2(b) of the Charter, it was justified under section 1 as a proportionate measure given its narrow scope and limited duration.
The sealing order was also upheld.