Liability of Independent Legal Counsel

The Alberta Court of Appeal indicates that it is almost impossible to find independent legal counsel (ILC) in discipline matters liable for malicious prosecution. In Clark v Hunka, 2017 ABCA 346, an accountant facing discipline objected to ILC because she was not truly independent. She prosecuted other cases at discipline before the same tribunal. The tribunal accepted that there was an appearance of bias created and directed a new hearing before a different panel with different ILC. Eventually, on appeal, the accountant had the proceedings stayed. The accountant sued ILC for malicious prosecution.

The Court dismissed the action as having no chance of success on two bases. First, an essential element of the tort of malicious prosecution is that the person initiated (or continued) the initial legal proceedings. ILC, as an advisor to the tribunal, does not have that role. This element could not be met.

Second, no particulars of malice against ILC were alleged. The Court held that “malice requires a willful and intentional effort on behalf of prosecutors to abuse or distort their proper role within the disciplinary system”. The Court said that “malice requires more than incompetence, inexperience, poor judgment, lack of professionalism, laziness, recklessness, honest mistake, negligence or even gross negligence”. A failure to appreciate an appearance of bias until it was raised does not constitute malice. In addition, malice would require actual bias, not an appearance of bias.

This second basis for the Court’s findings should be of assistance to prosecutors and tribunal members as well.

More Posts

Right-Touch Regulation Redux

Perhaps the most consequential document in professional regulation in the English-speaking world this century is Right-Touch Regulation published by the UK oversight body, the Professional

Reason Writing Omissions

Writing reasons for a regulatory decision is not easy, especially for non-lawyers. An administrative body’s reasons are the primary basis upon which a court will

Interim Orders – Take Two

The Alberta regulator for chiropractors got the interim order process right on its second try. In Basaraba v College of Chiropractors of Alberta, 2025 ABKB

Safeguarding

Most regulators screen complaints and reports as they arrive to assess the degree of risk presented and to prioritize matters appropriately. The UK regulator for