The review includes also reference to remarks such as those of Justice Vertes in Tanaka v. Certified General Accountants’ Assn. of the Northwest Territories, [1996] N.W.T.R. 301 (S.C.) at para. 39: 39 Finally, I have not ignored the applicant’s submissions to the effect that even the mere referral of a complaint to a committee of inquiry has a negative impact on the applicant. There is a detrimental effect on her professional reputation among her colleagues and potential clients as well as the costs to be incurred in defending a professional misconduct charge. This reinforces, in my view, a requirement for at least elemental fairness at the investigation stage.
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