In Gerasimov v. Ratayev (Ont CA, 2025) the Ontario Court of Appeal noted that an argument of 'inadequate reasons' may be met by referring to the record below, here in a case conference context:
[3] One of the reasons for judicial decisions noted by the Supreme Court in R. v. Sheppard, 2002 SCC 26, [2002] 1 S.C.R. 869, at paras. 46 and 66, is to permit meaningful appellate review. If the trial reasons “do not explain the ‘what’ and the ‘why’, but the answers to those questions are clear in the record, there will be no error”: R. v. G.F., 2021 SCC 20, [2021] 1 S.C.R. 801, at para. 70. However, if the answers are not on the record, “cursory reasons may obscure potential legal errors and not permit an appellate court to follow the trial judge’s chain of reasoning”: G.F., at para. 75. This was the case here. The lack of intelligible reasons showing a chain of reasoning means that there is no basis on which this court can decide the appeal on the merits. There needs to be an evidentiary record.
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