Does the disclosure of non-payment of legal fees constitute solicitor-client privilege?

Canada (Federal), Canada

The following excerpt is from R. v. Cunningham, [2010] 1 SCR 331, 2010 SCC 10 (CanLII):

Disclosure of non-payment of fees in cases where it is unrelated to the merits and will not cause prejudice to the accused is not an exception to privilege, such as the innocence at stake or public safety exceptions (see generally McClure and Smith v. Jones). Rather, non-payment of legal fees in this context does not attract the protection of solicitor-client privilege in the first place. However, nothing in these reasons, which address the application, or non-application, of solicitor-client privilege in disclosures to a court, should be taken as affecting counsel’s ethical duty of confidentiality with respect to payment or non-payment of fees in other contexts.

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