In R. v. Lawe (Ont CA, 2024) the Court of Appeal considered (and dismissed) a Crown appeal from a dismissal from a 'choking' charge [SS: the specific CCC 'choking' provision is unspecified, there are three difference]. Here, the court refers to a practice applied in domestic violence cases where the defendant is self-presenting:
[4] The respondent was self-represented. Unusually, for a trial involving allegations of domestic violence, the Crown had not applied for counsel to be appointed to cross-examine the complainant pursuant to s. 486.3(3) of the Criminal Code, R.S.C. 1985, c. C-46.
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