Richards vs Correctional Service Canada

Richards vs Correctional Service Canada

The Tribunal has authority to control its record and may order confidentiality post-dismissal where disclosure would create a real and substantial risk to life, liberty or security and no reasonable alternative exists; applying s.52 of the Act and Sherman Estate, the unredacted exhibit posed such a risk, so the...

Source-derived case information.

Citation
2026 CHRT 17
Parties
Complainant: Ryan Richards; Commission: Canadian Human Rights Commission; Respondent: Correctional Service Canada
Court
Canadian Human Rights Tribunal
Jurisdiction
Canada
Judgment Date
9 March 2026
Procedural Posture
Canadian Human Rights Complaint / Ruling on Confidentiality Post Dismissal
Outcome
Request to seal exhibit R-523 allowed; redacted version placed on official record; unredacted exhibit and CSC's request sealed and confidential
Legal Topics
Confidentiality Order, Sealing and Redaction of Exhibits, Functus Officio, Public Access to Hearings, Safety and Security of Inmates, Procedural Fairness
Source Language
english
Human Rights Administrative Law Privacy/confidentiality Corrections Law Confidentiality Order Sealing and Redaction of Exhibits Functus Officio Public Access to Hearings +2 more

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Legal principles 5 Authorities cited 7 Party arguments 2
Sign in to unlock

Parties

Ryan Richards

Complainant

Canadian Human Rights Commission

Commission

Correctional Service Canada

Respondent

Procedural Posture

Canadian Human Rights Complaint / Ruling on Confidentiality Post Dismissal

Legal Issues

  1. 1 Whether the Tribunal retains jurisdiction to order confidentiality after dismissing the underlying complaints
  2. 2 Whether exhibit R-523 should be sealed or a redacted version placed on the public record
  3. 3 Whether Correctional Service Canada was required to bring a formal motion for confidentiality

Ratio Decidendi

The Tribunal has authority to control its record and may order confidentiality post-dismissal where disclosure would create a real and substantial risk to life, liberty or security and no reasonable alternative exists; applying s.52 of the Act and Sherman Estate, the unredacted exhibit posed such a risk, so the redacted version is placed on the record and the unredacted exhibit and related request are sealed and confidential.

Court Disposition

Request to seal exhibit R-523 allowed; redacted version placed on official record; unredacted exhibit and CSC's request sealed and confidential

Orders

  • The Registry will place on the official record the redacted version of exhibit R-523 provided by CSC on December 2, 2025.
  • The original unredacted version of exhibit R-523 and CSC's request regarding it are designated confidential, sealed, and shall not be accessible to the public.