Tsatsi v College of Physicians and Surgeons of
Saskatchewan, 2018 SKCA
53, held that a physician’s defamation claim
against his regulator, his employer, and the government, should be
dismissed as a result of the defences of truth and qualified
privilege.
Dr. Tsatsi practiced as a radiologist in Saskatchewan. During a
review by the College of Physicians and Surgeons of Saskatchewan
(the “College”), concerns arose regarding his
competency. Two assessments by competency committees appointed by
the College each reported that Dr. Tsatsi failed to demonstrate the
competence required to practice independently. The College notified
the Ministry of Health of its concerns. The College, the Ministry,
and the Sunrise Health Region, Dr. Tsatsi’s employer, decided
to conduct a retrospective review of all diagnostic imaging studies
performed by Dr. Tsatsi and advise the public that the review was
occurring. The parties advised the public of their concerns with
Dr. Tsatsi,
