R. c. S.B.C.

R. c. S.B.C.

The trial judge did not err in proceeding without defence counsel because the appellant had delayed seeking representation, the court appointed counsel to conduct the key cross‑examination, the judge provided adequate procedural and substantive assistance throughout trial, and the evidence combined with the...

Source-derived case information.

Citation
2022 ONCA 171
Parties
Respondent: Sa Majesté la Reine; Appellant: S.B.C.
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
1 March 2022
Procedural Posture
Criminal Appeal / Appeal From Conviction in Court of Appeal
Outcome
Appeal dismissed
Legal Topics
Non‑consensual Distribution of Intimate Images, Criminal Harassment, Extortion by Libel, Mischief to Computer Data, Right to a Fair Trial, Self‑representation, Judicial Duty to Assist Unrepresented Accused, Disclosure
Source Language
fr
Criminal Law Criminal Procedure Appeal Law Non‑consensual Distribution of Intimate Images Criminal Harassment Extortion by Libel Mischief to Computer Data Right to a Fair Trial +3 more

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Summary, issues, holding and outcome

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Parties

Sa Majesté la Reine

Respondent

S.B.C.

Appellant

Procedural Posture

Criminal Appeal / Appeal From Conviction in Court of Appeal

  1. 1 Whether the trial judge erred in proceeding when the accused was unrepresented
  2. 2 Whether the trial judge failed to provide sufficient assistance to the unrepresented accused
  3. 3 Whether any judicial conduct amounted to bias or required intervention

Ratio Decidendi

The trial judge did not err in proceeding without defence counsel because the appellant had delayed seeking representation, the court appointed counsel to conduct the key cross‑examination, the judge provided adequate procedural and substantive assistance throughout trial, and the evidence combined with the appellant's admissions eliminated any reasonable possibility of prejudice; therefore the exercise of the trial judge's discretion was proper and the appeal fails.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Convictions affirmed