Introduction

In Zarabi-Majd, released in January 2025, the Divisional Court weighed in on whether the Toronto Police Services (“TPS”) Disciplinary Tribunal adequately accommodated a member with disabilities during the hearing process.[1] The Court concluded that the applicant, a police officer facing insubordination and discreditable conduct charges, had been offered adequate accommodations by the Hearing Officer, and emphasized that the process of finding reasonable accommodations must be collaborative between both parties.[2]

Zarabi-Majd gives us an opportunity to refresh and review the duty to accommodate in the context of self-regulating professions.