An enquiry under s. 231.4 into the financial affairs of a taxpayer ("Del Zotto") did not violate s. 7 of the Charter given that Del Zotto was not subpoenaed to attend or to give evidence or produce documents at the enquiry, and that the lawyer and business executive who was served with such a subpoena did not (unlike Del Zotto) face criminal charges under the Act. Accordingly, there was no violation of the "case to meet" and "right to silence" principles.
The requirement to appear and to bring documents was not sufficiently intrusive to justify imposing the Hunter standards under the aegis of section 8 of the Charter.