The following excerpt is from R. v. Peel Regional Police Service, Chief of Police, 2000 CanLII 22808 (ON SC):
While the arcane language of “showing cause” has been employed in the notice or citation in this case, because an allegation of criminal contempt is criminal or at least quasi‑criminal, the cited parties are entitled to the protection of the presumption of innocence and to the protection of having their guilt established beyond a reasonable doubt: Bhatnager v. Canada (Minister of Employment and Immigration), 1990 CanLII 120 (SCC), [1990] 2 S.C.R. 217 at 224, per Sopinka J. Summary Process
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