Thank you.
I want to make sure I understand the standard you apply before referral.
The Elections Canada website printout, under “Prosecutions”, says, “If the Commissioner believes on reasonable grounds that an offence under the Act has been committed...”. You may refer to it.
Reasonable grounds that an offence has been committed is a different standard than reasonable likelihood of conviction. One looks at evidence as it sits in front of you, and the second of course is evidence as it's contested in a trial. I'm wondering which one you apply.