C.A. No 112-51-974 - Appellant’s / Respondent’s Factum Template

Aug 31, 2026

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Ontario Court of Appeal factum template for an appeal in C.A. No 112-51-974, structured into Parts I–IV plus an appendix. It provides a case caption, instructions for selecting appellant or respondent, and placeholders for a short introduction and trial judge’s Charter analysis. The template includes a summary of facts involving an arrest, bail conditions under s. 515, alleged breaches, and stayed charges, followed by grounds of appeal on equality rights, reasonable bail, and demonstrable justification under s. 1 of the Charter. It concludes with the order requested and an authorities list.

LanguageEnglish

CategoryForms

FormatDOCX

Pages6

Reading Time2 min

AccessFree to download

PART I: INTRODUCTION

PART II: SUMMARY OF THE FACTS

PART III: GROUNDS OF APPEAL

Issue 1: Equality rights under s. 15

Issue 2: Reasonable bail under s. 11(e)

Issue 3: Justification under s. 1

PART IV: ORDER REQUESTED

APPENDIX A: AUTHORITIES TO BE CITED

C.A. No 112-51-974 COURT OF APPEAL FOR ONTARIO BETWEEN: THE ATTORNEY GENERAL OF ONTARIO (Appellant) - and - NINO BROWN (Respondents) ________________________________________________________ APPELLANT’S / RESPONDENT’S FACTUM (Select One) ________________________________________________________ NAME OF LAW FIRM Address of law firm Names of Counsel (Include First and Last Names) Of Counsel for the Appellant / Respondent (select one) Telephone: Fax: Email: PART I: INTRODUCTION This case is about [insert a short summary of the main issue raised by this appeal]. PART II: SUMMARY OF THE FACTS [do not alter] On August 1, 2020, Nino Brown was arrested outside of ‘The Old Jack’ and charged with assault with a weapon under section 267(a) of the Code and being in care or control of a vehicle while intoxicated contrary to section 320.14(1) of the Code. The Crown opposed his release from custody on the basis that he was likely to commit further offences and that pre-trial detention was therefore necessary for the protection of the public. Following a contested bail hearing, Mr. Brown was granted interim judicial release under section 515 of the Code, subject to certain conditions as specified by the bail judge. Mr. Brown’s release was subject to the following conditions: The accused will post a no cash bail of $3000 and report to a bail supervisor within two days of release from the remand centre and thereafter as directed. The accused will remain in the province of Ontario unless consent is granted by his bail supervisor. The accused will not attend any licensed establishment that serves alcohol. The accused will not possess or consume alcohol or any non-prescribed controlled substances during the term of his release, except within the confines of his home. The accused will be subject to a curfew of 10:00 pm. The accused will present himself at the door of his residence for any bail supervisor or peace officer who attends to confirm his compliance with his curfew. On October 28, 2020, police attended “The Old Jack” on an unrelated matter and found Mr. Brown in breach of his condition to not attend licensed establishments and to abstain from alcohol outside his home under the terms of his release. Mr. Brown was arrested under section 145(5) of the Code and remanded into custody. In December 2020, the Crown stayed Mr. Brown’s charge of assault with a weapon. Mr. Brown pleaded not guilty to the charge of failure to comply with the conditions of his release. He argues that the conditions of his bail, and in particular the prohibition on possession or consumption of alcohol outside the home: Violate his equality rights under section 15 of the Charter; Violate his right not to be denied reasonable bail without just cause under subsection 11(e) of the Charter; and Are not reasonable limits prescribed by law that can be demonstrably justified in a free and democratic society, per section 1 of the Charter. [This is where you will need to summarize the trial judge’s decision, by explaining how Justice Siddiqui decided on each of the Charter issues. All quotes should be indented and single-spaced (like this paragraph). They must be referenced immediately after the paragraph, noting the page or paragraph number of the quote.] PART III GROUNDS OF APPEAL Issue 1: Do the bail conditions imposed under s. 515(4) of the Criminal Code violate Mr. Brown’s equality rights as a person with a disability under s. 15 of the Charter? [Insert your firm’s argument on this issue. Refer to the explanatory notes, How to Prepare a Factum, for information on how to refer to cases and how to structure your argument.] Issue 2: Do the bail conditions imposed under s. 515(4) of the Criminal Code violate Mr. Brown’s right to reasonable bail as set out in s. 11(e) of the Charter? [Insert your firm’s argument on this issue. Refer to the explanatory notes, How to Prepare a Factum, for information on how to refer to cases and how to structure your argument.] Issue 3: If the

FAQs

What is the purpose of this factum template for C.A. No 112-51-974?

It organizes an appellate argument for the Ontario Court of Appeal, covering introduction, facts, Charter-based grounds of appeal, and the requested order, with an appendix for authorities.

What key facts and bail conditions should be summarized in Part II?

The template summarizes the arrest, the interim release under s. 515, the specific bail conditions imposed, and a later alleged breach leading to remand, along with any subsequent procedural developments.

What are the grounds of appeal outlined in Part III?

It sets out three issues: equality rights under s. 15, reasonable bail under s. 11(e), and whether any infringement can be demonstrably justified under s. 1.

Aug 31, 2026

Upload by Violet