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Reasons - Adequate Reasons Discussed (6). R. v. Blanco
In R. v. Blanco (Ont CA, 2026) the Ontario Court of Appeal considers a test for the adequacy of reasons for decision:The Test for Finding Reasons Insufficient
[22] On appellate review, reasons must be “sufficient in the context of the case for which they were given.” The reasons must be read as a whole, considering the issues at trial, to understand what was decided and why: R. v. G.F., 2021 SCC 20, [2021] 1 S.C.R., at paras. 68-69.
[23] Poor reasons are not an independent ground of appeal. Where reasons fail to explain the “what” and the “why” but those answers are clear in the record, there will be no error: G.F., at para. 70; R. v. R.E.M., 2008 SCC 51, [2008] 3 S.C.R. 3, at paras. 38-40. Put another way, reasons are not insufficient when “[t]he foundations for the judge’s decision” are discernable “in the context of the evidence, the submissions of counsel and the history of how the trial unfolded”: G.F., at para. 69; and R.E.M., at para. 17.
[24] Reasons must be both factually and legally sufficient. Rarely will there be cases in which one cannot understand the factual basis for the trial judge’s findings, i.e., what the trial judge decided and why. Legal sufficiency requires that lawyers be able to discern the viability of an appeal and that appellate courts be able to determine whether an error has occurred. This is a context-specific inquiry to be assessed in light of the live issues at trial; it must reflect and respect the presumption that “the trial judge understands the basic principles of criminal law at issue in the trial” and is not required to demonstrate knowledge of such principles: G.F., at paras. 71, 74; and R.E.M., at para. 45.
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