In R. v. Gibson (Ont CA, 2024) the Ontario Court of Appeal considers a criminal appeal, here where an issue was juror secrecy:
[16] As noted above, Ms. Gibson learned about the identity of the juror shortly after the verdict. The appellant’s counsel had some communications about the situation with the Crown Law Office (Criminal) and the office of the trial Crown. Both offices, quite rightly in my view, declined to investigate the juror for fear of running afoul of the juror secrecy rule, reflected in s. 649 of the Criminal Code.
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