R v Shakiem ANDERSON, 2018 OJ No. 5043 (Penny – SCJ):

[56] It must be remembered as well that this is a reverse onus case; the ladder approach does not apply. In my view the defendant has failed to discharge his onus of showing that his plan of supervision, given his antecedent behaviour, will sufficiently protect the
public or keep the public safe. I would therefore revoke bail on this basis.