Canada v. Title Estate, 2001 DTC 5236, 2001 FCA 106 -- summary under Paragraph 118.2(2)(e)

A certificate stating that "this person requires a supervised setting since January 31, 1995 due to medical illness. This person requires a 24-hour companion", did not satisfy the requirements of s. 118.2(2)(e) because it did not specify a mental or physical handicap from which the patient suffered, and the equipment, facilities or personnel that the patient required in order to obtain the care or training needed to deal with the handicap.