Is full and frank disclosure required for a jeopardy order to be issued?

Canada (Federal), Canada

The following excerpt is from Canada (National Revenue) v. Reddy, 2008 FC 208 (CanLII):

In Minister of National Revenue v. Rouleau (1995), 95 D.T.C. 5597, my colleague Justice Gibson ruled that full and frank disclosure did not require the disclosure of material that is irrelevant to the test for the issuance of a jeopardy order under the Act.

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