have information on, and the applicant has not sought leave to
submit, evidence on the source of the opinions in the report.
There has been no cross-examination.
 The use I make of this report is limited: It confirms that
the appropriate management of inmates using administrative
segregation continues to be a contentious issue in Canada.
 The applicant filed service of a notice of constitutional
question on the Attorney General of Ontario and entered it as an
 The applicant claims public interest standing. In accordance with the test laid out in Downtown Eastside Sex Workers
United Against Violence Society v. Canada (Attorney General),
 2 S.C.R. 524,  S.C.J. No. 45, 2012 SCC 45, it asserts
that the challenge to the legislative authorization for solitary
confinement is a serious justiciable issue; that as an advocate for
civil liberties, it has a genuine interest in the outcome; and that
this application is a reasonable and effective means of bringing
the case given the difficulty inmates subjected to administrative
segregation would have in bringing a court application that
draws heavily on expert evidence.
 The respondent maintains that the applicant has standing only to ask for a declaration of invalidity pursuant to s. 52(1)
of the Charter and that such a declaration is only available,
if the applicant establishes that the statutory scheme of the
administrative segregation provisions of the Corrections and
Conditional Release Act cannot be constitutionally administered.
The Applicant Cannot Resort to S. 24(1) of the Charter
 The respondent cautions that public interest standing
does not grant standing to seek a s. 24(1) remedy.
 The respondent maintains that the applicant cannot
bring a s. 24(1) Charter application, impugning the Correctional
Service of Canada’s past or present practice of administrative
segregation, claiming that only a party alleging an infringement
of its own Charter rights can resort to s. 24(1).
 I accept the respondent’s submissions in this regard.
 Apart from the plain meaning of the words used in
s. 24(1) of the Charter, namely, “Anyone whose rights or freedoms, as guaranteed by this Charter, have been infringed or
denied may apply . . .”, the issue appears to have been addressed
by the Supreme Court in R. v. Ferguson,  1 S.C.R. 96,
 S.C.J. No. 6, 2008 SCC 6. In that case, the accused, an
RCMP officer, shot and killed a person held in a cell at an RCMP