“Rowbotham”
Canada
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The Ontario Court of Appeal, in R. v. Rowbotham, found that sections 7 and 11(d) of the Canadian Charter of Rights and Freedoms create a right to counsel if necessary for a fair trial, and that the court can order federally funded counsel in situations where an accused cannot afford counsel but is not eligible for legal aid, and where the proceedings are complex and there is a likelihood of imprisonment.
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