In R. v. D.L. (Ont CA, 2025) the Ontario Court of Appeal dismissed criminal cross-appeals - here by the Crown from acquittals for charges of "three counts of sexual assault and one count of extortion" - but by the defendant against convictions of numerous other counts "all of which alleged assaults and uttering threats".
Here the court cites a useful case on 'threats':
[37] It is true that “a veiled reference may constitute a threat if it is sufficient, in light of all the circumstances, to convey to the complainant the consequences which he or she fears or would prefer to avoid”: R. v. Barros, 2011 SCC 51, 338 D.L.R. (4th) 219, at para. 61. ....
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