Importantly, although the court in Telezone reviewed the Minister’s refusal to disclose records on a standard of correctness, it was held at para. 40: … the fact that courts have applied a deferential standard of review under Ontario’s freedom of information statute (see, for example, John Doe v. Ontario (Information and Privacy Commissioner) (1993), 1993 CanLII 3388 (ON SCDC), 13 O.R. (3d) 767 (Div. Ct.)) has little relevance, if any, to the federal access statute because, as already noted, under the Ontario Act, the decisions being reviewed are those of the independent Information Commissioner, not of the institution head.
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