The applicant, a physician, sought judicial review of the decision of the Registrar of the College of Physicians and Surgeons of Ontario to appoint investigators to investigate his practice.
The investigations arose from resolutions of the Quality Assurance Committee and a patient complaint.
The applicant refused to comply and raised constitutional and procedural fairness issues.
The Divisional Court dismissed the application for judicial review on the grounds of prematurity, holding that administrative proceedings should run their full course before judicial intervention, absent exceptional circumstances.