Can a parent secretly record an interview with a third party as evidence in a medical malpractice case?

There are few reported cases of recordings made of third parties. In the case of Fattali v. Fattali,[3] a father secretly recorded an interview with the children’s paediatrician. Justice Vogelsang held the evidence inadmissible and determined that such forays into the gathering of potential evidence are to be strongly discouraged and that proceedings involving the best interests of children should not be based on the product of calculated subterfuge. He also held that it did not help the father’s case to be plotting tricks or deceit to advance his case.