R v. Sakhiyar, 2018 ONSC 5767 (Bale):

[7] I do not accept defence counsel’s argument that the bail justice erred in law by failing to apply the “ladder principle”. This was a reverse onus bail hearing to which the “ladder principle” does not apply.” In this regard, I accept the following statement of law contained in Trotter, The Law of Bail in Canada, at page 6-9 (2017 — Rel.2):

The ladder principle is inapplicable to situations in which a reverse onus provision in s. 515(6) is triggered. When this subsection was enacted in 1976, Parliament made no attempt to reconcile the reverse onus provisions with s. 515(3). It follows that when the onus is on the accused, he or she ought to be required to justify why the most onerous form of release should not be imposed. This may well be the reality in practice.