In the environment of a prison, segregation and loss of the prospect of release are the most serious consequences a prisoner can face. Winters v. Legal Services Society, 1999 CanLII 656 (SCC), [1999] 3 S.C.R. 160. While the prospect of solitary confinement may not be enough in every case to justify legal representation at the hearing, that prospect coupled with the loss of early release eligibility strongly promotes representation by counsel. (b) Complexity
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