Financing infrastructure, whether it involves maintaining the infrastructure we’ve inherited, building the infrastructure we need today, or anticipating the infrastructure that will be required in the future, is one of the greatest challenges facing modern societies. Civil, industrial and energy infrastructure are essential assets for the common good, and their maintenance and modernization require colossal investments. However, public finances are limited, which restricts the ability of governments to act alone. In this context, it is crucial to use all available financing methods by incorporating private capital and designing innovative financial tools. In this spirit, we will be publishing a series of six articles devoted to infrastructure financing in Quebec and Canada. In them, we will discuss the issues related to these strategic investments and highlight realistic solutions to address them. This first article begins by providing an overview of the situation in Quebec and Canada, and then looks at the current challenges and the solutions that will shape the infrastructure of tomorrow. The Current Situation in Quebec and Canada In Quebec, public investment in infrastructure is governed by the 2025-2035 Québec Infrastructure Plan (the “QIP”), which provides for the injection of $164 billion over 10 years1. The QIP is a government planning document identifying and prioritizing major infrastructure projects in all public sectors. The most recent version of the QIP pays particular attention to the longevity of the existing infrastructure. Keeping current public assets in good condition despite the chronic maintenance backlog will absorb nearly 65% of the planned funding. The investments are primarily directed towards road transport ($36 billion), healthcare ($28 billion), education ($23 billion), and public transit ($9 billion). In terms of energy infrastructure, Quebec has embarked on a major transformation. According to Hydro-Québec’s Action Plan 2035, the province has set itself the objective of doubling its electricity generation capacity by 2050, with an intermediate target of adding 60 terawatt-hours (TWh) in 2035. This plan involves investments of over $100 billion for the construction of new dams, wind farms, and electric transmission networks in order to meet the growing demand related to electric vehicles and the energy transition2. Energy issues are a top priority across Canada. We are witnessing a resurgence of nuclear power, with several provinces (Ontario, New Brunswick, Alberta and Saskatchewan) choosing to develop small modular reactors (SMRs) to decarbonize their energy generation and ensure energy security3. At the same time, there is strong pressure to build new pipelines for hydrocarbon exports, particularly to Asia and Europe, for the energy transition and supply security4. At the federal level, the 2025 budget gives concrete form to Prime Minister Mark Carney’s investment ambitions5 to address critical issues such as housing, public transit, climate resilience, and accessibility. One of the flagship programs at the federal level is the creation of Build Canada Homes6, a new agency established in September 2025 with a budget of $13 billion. This program aims to “supercharge” the construction of affordable housing, to leverage public land, and to make use of modern techniques such as modular and mass timber construction. Meanwhile, on September 11, the Prime Minister announced an initial nationwide series of energy, port, and mining projects. He also expressed the desire to add other projects in the coming years. This list includes the expansion of the Port of Montreal in Contrecœur. Current Challenges The asset maintenance deficit, that is, the estimated amount of infrastructure in poor or very poor condition, is estimated by the Quebec government to be over $40 billion in 2025. That’s the amount that would need to be invested today simply to bring systems back to an acceptable state. In addition to rehabilitating aging infrastructure, it’s also important to make existing infrastructure more resilient; for example, in 2024, the flooding further to Hurricane Debby caused $2.5 billion in damage in southern Quebec7. And infrastructure must be low-carbon, in order to allow Quebec to achieve its climate objectives in terms of greenhouse gas emission reduction. Furthermore, modernization must incorporate climate change adaptation, cybersecurity, and smart grids. We need to accelerate the construction of new infrastructure to ensure Canada’s prosperity. In 2023, the Canada Mortgage and Housing Corporation noted that 3.5 million new homes will be needed by 2030 to restore affordability in the country8. Added to this are the needs for energy, transportation and healthcare infrastructure, which are intensifying due to population growth, the energy transition, the desired reindustrialization and, in the future, the increasing use of energy-intensive artificial intelligence. However, in addressing these challenges, governments are facing a critical lack of liquidity. The 2025 federal budget in Ottawa includes a $78-billion deficit9, while the Government of Quebec’s budget includes a record $13.6-billion deficit10. These structural deficits considerably limit their budgetary leeway and force them to choose between the different issues our societies face. At the municipal level, municipalities are legally required to table a balanced budget. Given the rising expenses and the electoral need to not increase taxes significantly, potential investments are limited. Potential Solutions: Private Capital and Financial Innovation Faced with increasing pressure on public finances, particularly at the municipal level, governments can no longer bear the cost of modernizing and developing infrastructure alone. In this context, looking to private capital and financial innovation can bridge the gap between public financial needs and capacities. Some of the top solutions are public-private partnerships, smart pricing (tolls, usage fees, dynamic pricing), and mobilizing institutional savings, particularly through pension funds, insurance companies and investment funds. Pension funds and insurance companies are particularly attracted to infrastructure projects. Their long-term investment horizon is well aligned with the lifespan of the projects and the stable revenue streams they generate. For example, the Fonds de solidarité FTQ has a fund dedicated to real estate11. Banks are key partners in infrastructure projects. They offer hybrid financing, combining low-interest loans and government backing to secure investments in critical projects such as highways, bridges and railways. It is also worth noting that investment funds are increasingly turning to infrastructure financing, as evidenced by the example of BlackRock12. BlackRock recently strengthened its position in this sector by acquiring Global Infrastructure Partners for $12.5 billion, creating a leading investment platform in private infrastructure markets. This acquisition, combined with strategic partnerships with players like Microsoft, aims to meet the growing demand for essential digital and energy infrastructure to support technological advances and the digital economy. Furthermore, the purchase of key Panama Canal ports for $23 billion demonstrates BlackRock’s commitment to critical infrastructure assets globally. These investments, motivated by the desire to diversify portfolios and protect against inflation, allow for the integration of professionals in the execution of projects. While these approaches make it possible to diversify funding sources, accelerate project completion and distribute risks between the public and private sectors, they also raise issues of governance, transparency and social acceptability, which require special attention to protect the long-term public interest. Infrastructure financing in Quebec and Canada must evolve to address the maintenance deficit, the requirements of the energy transition, and increasing budgetary constraints. Private capital, whether from pension funds, banks or specialized funds, offers indispensable support for collective efforts. Beyond the diversification of funding sources, the emergence of contractual and financial innovations, such as performance contracts, green bonds and risk-sharing models, opens up new ways to attract private investors while protecting the public interest. Our next article will discuss these new tools and mechanisms in detail, as well as the conditions for their success in Quebec and Canada. Government of Québec (March 25, 2025). Plan québécois des infrastructures 2025-2035 : le gouvernement du Québec se donne les moyens de réaliser ses engagements et de soutenir l’économie québécoise.  https://www.quebec.ca/nouvelles/actualites/details/plan-quebecois-des-infrastructures-2025-2035-le-gouvernement-du-quebec-se-donne-les-moyens-de-realiser-ses-engagements-et-de-soutenir-leconomie-quebecoise-61815 Hydro-Québec (2 novembre 2023). Vers un Québec décarboné et prospère. Plan d’action 2035 d’Hydro-Québec. https://www.hydroquebec.com/data/a-propos/pdf/plan-action-2035.pdf Canada Energy Regulator (August 20, 2025). Market Snapshot: Canada’s role in small modular reactor (SMR) technology. https://neb-one.gc.ca/en/data-analysis/energy-markets/market-snapshots/2025/market-snapshot-canadas-role-in-small-modular-reactor-smr-technology.html Underground Infrastructure (September 2025). Canada eyes new pipelines to boost energy security, cut U.S. reliance. https://undergroundinfrastructure.com/magazine/2025/september-2025-vol-80-no-9/features/canada-eyes-new-pipelines-to-boost-energy-security-cut-us-reliance Prime Minister of Canada (November 2025). Prime Minister Carney shares Budget 2025 plan to build communities strong. https://www.pm.gc.ca/en/news/news-releases/2025/11/05/prime-minister-mark-carney-shares-budget-2025-plan-build-communities Government of Canada (September 14, 2025). Prime Minister Carney launches Build Canada Homes to supercharge homebuilding across the country. https://www.pm.gc.ca/en/news/news-releases/2025/09/14/prime-minister-carney-launches-build-canada-homes Insurance Bureau of Canada (September 13, 2024). The costliest severe weather event in Quebec’s history – August flooding caused nearly $2.5 billion in insured damage. https://www.ibc.ca/news-insights/news/the-costliest-severe-weather-event-in-quebec-s-history-august-flooding-caused-nearly-2-5-billion-in-insured-damage Canada Mortgage and Housing Corporation (June 23, 2023). Housing Shortages in Canada – Update on how much housing we need by 2030. https://assets.cmhc-schl.gc.ca/sites/cmhc/professional/housing-markets-data-and-research/housing-research/research-reports/2023/housing-shortages-canada-updating-how-much-we-need-by-2030-en.pdf CBC (November 4, 2025). Budget fédéral : dépenses de taille, compressions humbles et un déficit qui se creuse. https://ici.radio-canada.ca/rci/fr/nouvelle/2205360/budget-federal-depenses-compressions-investissements-deficit-2025 Royal Bank of Canada (March 25, 2025). Quebec Budget 2025: Record deficit and a long and conditional path to balance. https://www.rbc.com/en/economics/canadian-analysis/provincial-and-fiscal-outlooks/provincial-budgets-and-economic-statements/quebec-budget-2025-record-deficit-and-a-long-and-conditional-path-to-balance/ Fonds immobilier de solidarité FTQ (2025). Who we are. https://www.fondsftq.com/en/business/fonds-immobilier/who-we-are Business Economy (March 6, 2025). Why BlackRock is Investing Heavily in Infrastructure. https://www.businesseconomy.com/latest-news/why-blackrock-is-investing-heavily-in-infrastructure/

In a previous Bulletin, the authors broadly outlined the legal framework that applies to export controls, as well as the challenges surrounding large language models in artificial intelligence in an era of knowledge sharing. Given that a number of legal and geopolitical developments covering various aspects of this topic took place in 2025, a brief overview is timely on the potential implications for the development of your AI projects, with a special mention of generative AI (or “GenAI”), as the new year begins. What are export controls? Export controls establish rules designed to curb the risk of transferring military, strategic and dual-use (civilian and military) goods and technologies to destinations deemed contrary to national security interests. Such technologies can take on various forms, ranging from physical hardware to technical information. In Canada, export controls are based on a licensing system, under which permits are given based on a series of items listed on the Export Control List (“ECL”) under the Export and Import Permits Act (“EIPA”). To find out if parts of your AI projects are subject to export controls, you should primarily (but not exclusively) refer to that list and to the guide prepared to better understand the list. Key events in 2025 Order SOR/2025-89  On March 7, 2025, an Order amending the ECL was published in the Canada Gazette, in an effort to include emerging technologies that are increasingly faster and more scalable, the capabilities of which raise concerns about potential adversarial military applications.1 Of particular interest in this context, subitem 5506(1) of the schedule to the ECL has been replaced by a number of paragraphs and subparagraphs. But what do these changes mean for AI projects in practice? The amendments made to subitem 5506(1) do not target AI applications (algorithms, models, data), but rather: extreme ultraviolet (“EUV”) lithography equipment, namely EUV masks and reticles making it possible to use this technology to manufacture advanced integrated circuits; cryogenic cooling equipment and ultra-sensitive amplifiers for quantum computers; advanced semiconductor materials; development and production softwares related to certain of the foregoing technologies.2 In other words, subitem 5506(1) targets the industrial toolbox used to build advanced computers, in particular through its inclusion of EUV lithography, which is used for cutting-edge integrated circuits and quantum computers that are revolutionizing the world of advanced computing. It can therefore be said that these rules affect the AI industry because of a form of hardware dependence, since tight control over these infrastructure manufacturing technologies necessarily affect the ability of a country or company to develop and operate advanced AI. In sum, these latest amendments are simply the continuation of those made in the previous year’s Order, which targeted the fields of quantum computing and advanced semiconductor manufacturing in particular (GAAFETs, representing next-generation integrated circuits).3 It has yet to be ascertained how the aforementioned orders will directly affect typical GenAI projects (model development, AI SaaS services, etc.). Those who will experience the more direct repercussions are suppliers of advanced computing equipment and businesses doing R&D on semiconductors, integrated circuits and quantum computing. Notice to Exporters No. 1159 Apart from the technical components, a certain complexity arises when we understand that the definition of a “technology” subject to export controls within the meaning of the law is meant to be broad, and that it includes technical data, technical assistance and information necessary for the development, production or use of an item appearing on the ECL. In other words, the scope of the technologies concerned goes beyond simple physical components or equipment. This is especially true given the proliferation of often cross-border cloud-based solutions, which make technical knowledge accessible digitally and circulate it far and wide. Given this context, it is appropriate to read the Guidance on the movement to and storage of controlled technology in the Cloud (Notice to Exporters No. 1159), published in November 2025 by the Government of Canada. The document was prepared to clarify instances when the use of cloud services constitutes a transfer of controlled technology under the EIPA, requiring a permit.4 In summary, the guidelines state that: it may be considered a transfer if a controlled technology is disclosed from a place inside Canada to a place outside Canada; a controlled technology is considered disclosed if it is sent from Canada and stored in a foreign location in a way that creates a reasonable possibility that a person located outside Canada would be in a position to examine that technology; a reasonable possibility means more than a mere possibility, but less than the standard of “more likely than not”; the location of servers hosting controlled technology only matters if it affects the reasonable possibility that the technology could be disclosed outside Canada; in general, it is considered a transfer when a person located outside Canada holds decryption keys or routine access rights that create more than a remote possibility that the technology may be examined, or when a cloud service provider creates an unencrypted backup copy that contains controlled technology to restore a system after an incident, and that such copy is stored on servers outside Canada where foreign administrators can access it; when cloud services are used, both the owner of the controlled technology and the cloud service provider have a degree of care and control of the technology. Thus, not only is there a risk of knowledge sharing where items directly listed on the ECL are involved (whether to manufacture them or otherwise), but the possibility of violating export controls also exists because of the interaction between cloud services and the knowledge that could be transferred (within the meaning set out above), if the cloud contains information about or relates to a controlled technology. Considerations regarding GenAI What about GenAI projects? Despite all of the above, these projects may still suffer indirect repercussions, and not only on highly technical components. You will need to exercise a certain degree of caution regarding the compliance of your GenAI projects because of the amount of information they can accumulate through the various layers of their structure. Training data There are the data used during the GenAI’s learning phase, before it is rolled out. The amount of this data can be massive, and it can be structured or unstructured. It is used to provide a knowledge base for the model and enable it to produce relevant outputs when it is given inputs. The learning phase is risky if the datasets contain controlled technical information and if the data can be regurgitated or combined when users use the GenAI. The GenAI’s weights, filters, and other operating parameters These parameters can be compared to physical control buttons—they are adjusted during the GenAI’s training and during the configuration of the solution that uses it. They determine how much each input element will influence the response and refine the model (i.e., the structure that allows the GenAI to interpret inputs and generate outputs). In the United States, weights in particular are a hot topic considering the country’s export policy, under which they can constitute key parameters for the most advanced AI models. Inputs This is the data provided by users to generate relevant outputs (e.g., text, images, structured data) when the GenAI is already rolled out. Such data is used to trigger a response or behaviour from the model. Just like with training data, inputs will be critical depending on the use made of the model and the information disclosed to obtain a response. Conditions consistent with legal requirements must be provided to prevent the model from being contaminated by sensitive data after it is rolled out, especially if it stores all the inputs provided to it for its continued learning. Outputs This is what GenAI generates in response to inputs. Outputs can be in the form of text responses or images, codes, or even data-based predictions. Given the above, it will be challenging depending on the datasets conveyed by the GenAI, to ensure that outputs do not violate export controls, as they could make it possible to indirectly obtain information the direct access to which would otherwise be prohibited. Conclusion We can imagine that the recent changes to export controls in Canada are just the beginning of an effort to address new concerns arising from this rapidly changing and ever more powerful technology. Export controls are also not devoid of a diplomatic context. For now, making AI subject to export controls seems to be the preferred mechanism to curb the exponential powers of such technology in Canada. The extent to which this will be done remains to be seen and will be interesting to follow. Government of Canada, Order Amending the Export Control List: SOR/2025-89 (March 7, 2025): Canada Gazette, Part II, Volume 159, Number 7: Order Amending the Export Control List: This is not an exhaustive list, but rather a few relevant examples that apply to advanced computing. Government of Canada, Order Amending the Export Control List: SOR/2024-112 (May 31, 2024): Canada Gazette, Part II, Volume 158, Number 13: Order Amending the Export Control List: Government of Canada, Notice to Exporters No. 1159 – Guidance on the movement to and storage of controlled technology in the Cloud (amended November 10, 2025): Notice to exporters no 1159 – Guidance on the movement to and storage of controlled technology in the Cloud

In the recent decision in Hashem c. Canada Life Assurance Company,1 rendered on January 12, Justice Karyne Beaudry of the Court of Québec reiterates the importance of doctors respecting their ethical obligations and preserving their professional independence when issuing a medical certificate in support of a disability insurance claim. Context of the insurance claim In this case, the plaintiff, Rayan Hashem (“Mr. Hashem”), representing himself, was claiming $67,133.28 in disability insurance benefits from the defendant, The Canada Life Assurance Company (“Canada Life”), under two credit insurance contracts issued for Royal Bank of Canada clients: one for a mortgage loan and the other for his line of credit. Mr. Hashem was also claiming $10,000 in moral damages due to Canada Life’s refusal to pay the benefits he believed were owed to him. On January 4, 2019, Mr. Hashem’s treating physician, Dr. Samuel Issid, diagnosed his patient with an adjustment disorder with depressive mood following an episode of psychological harassment at work. He concluded that there was a total incapacity for work for an indefinite period of time. Mr. Hashem then submitted an initial claim for disability insurance benefits, which was accepted by Canada Life. Upon expiry of the 60-day waiting period stipulated in the insurance contracts, Canada Life paid him benefits. As of June 2019, Mr. Hashem’s health condition was improving. Dr. Issid believed that returning to his job as a sales representative at Meubles Léon was impossible, but that he could do another job. On July 29, 2019, Dr. Issid noted that Mr. Hashem could gradually return to work starting that day. In his medical note dated August 7, 2019, he indicated that Mr. Hashem’s adjustment disorder was resolved. On August 6, 2019, Canada Life notified Mr. Hashem that the disability benefit payments would cease as of September 2019. From August 2019 to November 2019, Mr. Hashem performed paid transportation work for Uber. On October 4, 2019, Mr. Hashem consulted Dr. Issid again because he felt he was experiencing a relapse of his adjustment disorder. Dr. Issid found that he was indeed affected by an adjustment disorder with depressive mood, but believed he could do something else elsewhere and requested an expert opinion from the CNESST.  Dr. Issid did not prescribe medical leave, and Mr. Hashem continued to drive for Uber after this medical consultation. He stopped doing this job in November 2019, because “the job was not suitable for him” [translation], as he stated during the hearing. It was not until January 22, 2020, that Mr. Hashem consulted Dr. Issid again, still for his adjustment disorder. On that date, Dr. Issid noted the following: Not seen since October. Holds Uber taxi licence, studying to be a real estate broker. Lazy person, has not worked and wants two more weeks of pay at the expense of the CSST. Expert opinion already requested in October; I can’t help him and I don’t want to see him again for this case. [translation] Beginning in March 2020, Dr. Issid suspended his medical practice until September 2020 due to the COVID-19 pandemic. On April 8, 2020, Mr. Hashem consulted Dr. Yves I-Bing Cheng. The purpose of the consultation was to obtain “a medical document to reactivate his file and be able to claim insurance” [translation]. Dr. Cheng stated in his medical note that he could not sign such a document, as he had not been involved in Mr. Hashem’s case. He also noted that Mr. Hashem had seen Dr. Issid three times since August 2019 and that he could have spoken to him about it on those occasions. On September 24, 2020, Mr. Hashem returned to see Dr. Issid, who, at his request, filled out the Canada Life Disability Benefit Claim Form. On it, Dr. Issid indicated that Mr. Hashem became disabled on December 14, 2018, and that his condition initially improved, only to deteriorate later due to COVID-19. Mr. Hashem submitted this form to Canada Life to support his new claim for disability benefits. At the hearing, the Court gave little credence to this form completed by Dr. Issid: first, Justice Beaudry noted that Dr. Issid had found that Mr. Hashem’s disorder was resolved in August 2019, and secondly, she noted that Dr. Issid did not see Mr. Hashem again between February and September 2020. She was of the opinion that the diagnosis seemed to be based more on assumptions than on clinical observations. She found that the form was completed at Mr. Hashem’s insistence. On February 10, 2021, Canada Life informed Mr. Hashem that it refused to pay further disability benefits because he did not meet the definition of total disability under the policies, in particular because he had not provided satisfactory evidence of his disability. On March 26, 2021, Mr. Hashem submitted another claim for benefits, this time supported by medical forms completed by Dr. Yves I-Bing Cheng. In them, Dr. Cheng indicated that Mr. Hashem had been totally disabled since December 14, 2018, due to an adjustment disorder with anxious-depressive mood, and that no date for his return to work was planned. Dr. Cheng mentioned the following in his medical note on the same day: I filled out the insurance form with the patient, point by point, to make sure that everything complied with the patient’s wishes. [translation] This new claim was also rejected by Canada Life. The Court found that the information recorded on the form completed by Dr. Cheng had little to no credibility. It is important to note that neither of Mr. Hashem’s treating physicians testified at the hearing to contextualize or explain their diagnoses. No expert report was submitted for the plaintiff. In its defense, Canada Life produced the expert opinion of a psychiatrist, Dr. Paul-André Lafleur, who testified at the hearing. Justice Beaudry notes that Dr. Lafleur had been practicing psychiatry for 40 years, that his testimony was clear, and that his findings were supported by facts that he himself observed during an interview conducted with Mr. Hashem, or that emerged from extracts of his medical records or from the CNESST. Dr. Lafleur concluded that Mr. Hashem’s medical condition between August 2019 and December 2022 did not render him incapable of holding a sales representative position, although he acknowledged that he could not hold this position with his former employer. Justice Beaudry found Mr. Hashem’s testimony to be not very credible and noted that Mr. Hashem had a subjective perception of his inability to work. He refused to take any position other than the one he held at Meubles Léon before his claim to Canada Life. Based on the evidence, Justice Beaudry found that Mr. Hashem had not demonstrated that he was entitled to disability insurance benefits as of October 4, 2019. Given his skills and abilities in the field of sales, he could hold a sales representative position elsewhere than with his former employer. Canada Life was therefore justified in rejecting his claims for disability benefits in September 2020 and March 2021. Credibility of the insured’s medical evidence Although the doctors consulted in the context of the new benefit claims maintained the diagnosis of adjustment disorder as of October 4, 2019, the Court emphasizes that this diagnosis alone was not sufficient to establish the existence of a disability meeting the contract’s criteria, especially since this diagnosis was supported by inconsistent and unreliable medical evidence. The mere fact that a doctor has filled out a claim form does not automatically entitle the insured to compensation: the definition set out in the contract remains applicable and the criteria must be met.2 The ethical obligations of a doctor and the consequences of writing an unfounded medical certificate In this case, the Court reminds doctors of the importance of supporting their medical certificates with objective clinical observations and avoiding simply endorsing the requests of their patients. Medical certificates issued at the insistence of patients, or by giving in to their pressure, are considered false certificates.3 The ethical obligations of doctors prohibit them from issuing such certificates and, more generally, from providing information they know to be inaccurate,4 in particular in the aim of allowing a patient to obtain a benefit to which they are not entitled.5 Conclusion  Medical certificates must be founded exclusively on medical grounds arising from an actual assessment of the patient’s condition.6 They must not be founded on extraneous or irrelevant considerations.7 In addition to damaging the credibility of the medical profession, issuing false certificates has significant repercussions in the workplace and generates considerable financial costs for employers, insurers, and the government.8 Key points to remember In disability insurance matters, the terms and definitions of the insurance contract are paramount and are the main elements that must guide the interpretation and determination of the insured’s disability status. Medical certificates and claim forms are only elements used in determining the insured’s state of disability and are not proof of disability in and of themselves. A medical diagnosis is not automatically a sign of disability. It is important for functional limitations to be identified. Having a qualified expert who is able to comment on the insured’s medical condition at the hearing can make a big difference in the outcome of litigation. Hashem c. Canada Life Assurance Company, 2026 QCCQ 41. G.G. c. SSQ, société d’assurance-vie, 2017 QCCQ 9442, par. 19 COLLÈGE DES MÉDECINS DU QUÉBEC, ORDRE DES CONSEILLERS EN RESSOURCES HUMAINES AGRÉÉS, ORDRE DES INFIRMIÈRES ET INFIRMIERS DU QUÉBEC, Certificats médicaux et travail, (Medical Certificates and Work), June 2025, p. 14, online: https://cms.cmq.org/files/documents/Guides/gui-certificats-medicaux-travail.pdf Code of ethics of physicians , CQLR, c. M-9, r. 17, s. 7 and 85. Ibid. , s. 97-98. Médecins (Ordre professionnel des) c. Larouche, 2018 CanLII 6869 (QC CDCM), para. 184. Médecins (Ordre professionnel des) c. Léonard, 2025 QCCDMD 27 (CanLII), para. 169. Op. cit. note 3.