R. v. M.D.

R. v. M.D.

The Court held that because defence counsel did not give appropriate notice and the Crown was not permitted to call evidence of how prosecutorial discretion was exercised, and because there was no evidence or findings establishing abuse of discretion, the trial judge lacked jurisdiction to award solicitor and client...

Source-derived case information.

Citation
1998 NSCA 47
Parties
Appellant: M. D.; Respondent: Her Majesty the Queen in Right of the Province of Nova Scotia
Court
Nova Scotia Court of Appeal
Jurisdiction
Canada
Judgment Date
9 January 1998
Procedural Posture
Criminal Appeal (certiorari Application Below) / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Charter S.7, S.24(1) Remedy, Prosecutorial Discretion, Solicitor and Client Costs, Certiorari, Abuse of Discretion, Procedural Notice
Source Language
en
Criminal Law Constitutional Law Administrative Law Charter S.7 S.24(1) Remedy Prosecutorial Discretion Solicitor and Client Costs Certiorari +2 more

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Parties

M. D.

Appellant

Her Majesty the Queen in Right of the Province of Nova Scotia

Respondent

Procedural Posture

Criminal Appeal (certiorari Application Below) / Court of Appeal Judgment

  1. 1 Whether a trial judge has jurisdiction to award solicitor and client costs against the Crown based on alleged abuse of prosecutorial discretion without appropriate notice and without evidence of abuse
  2. 2 Whether the Crown was denied a fair opportunity to call evidence regarding the exercise of prosecutorial discretion when defence sought a Charter remedy immediately after acquittal
  3. 3 Whether the appellate court should intervene and overturn the quashing of the costs order

Ratio Decidendi

The Court held that because defence counsel did not give appropriate notice and the Crown was not permitted to call evidence of how prosecutorial discretion was exercised, and because there was no evidence or findings establishing abuse of discretion, the trial judge lacked jurisdiction to award solicitor and client costs against the Crown; thus the quashing of that costs order was correct.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Order of Justice Hood quashing Provincial Court Judge Atton's order for solicitor and client costs against the Crown is upheld