For all of the above reasons, CACL, jointly with CCD, have taken the unusual step of bringing a motion to intervene on the leave application, to ensure that this Court has full insight into the
deficient and unbalanced
factual record, and the resulting impact on persons with intellectual disabilities, in assessing whether to grant leave to appeal in this case.
Since the majority frames the issue as a dispute over the interpretation of a contract, and the
factual matrix surrounding the making of the settlement contract was not materially in dispute, it is possible to conclude the
record before the Chambers Judge was not
deficient: