Wikipedia:Articles for deletion/R. v. Gowan


 * The following discussion is an archived debate of the proposed deletion of the article below. Please do not modify it. Subsequent comments should be made on the appropriate discussion page (such as the article's talk page or in a deletion review).  No further edits should be made to this page.

The result was keep. Merging is an editorial discretion. (non-admin closure) GeoffreyT2000  ( talk,  contribs ) 00:14, 30 March 2017 (UTC)

R. v. Gowan

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A very obscure ruling by a provincial court (not some supreme court decision), which has been referenced by one newspaper article the day after the ruling, one column, and a single passing mention (one or two lines) in a book (Google search revealed no other usable sources). Searching for "R. v. Gowan" 1998 or "R v Gowan" Ottawa returns less than 10 Google hits and no Google Books hits.

Fails WP:BLP1E and WP:NCRIME (there are even no Google hits at all for her full name apart from this article, we shouldn't be the ones revealing the full name of a BLP only "known" for such a negative case).

The article also contains incorrect allegations about Gowan (again a BLP violation), e.g. "as a result of her desire to test the limits of the R. v. Jacob (1996) Ontario court decision legalizing non-commercial toplessness": the source for this makes it clear that the police wanted to test the limits of the court decision, and choose the case of Gowan as a test case: Gowan herself had no intention of testing the limits of Jacob (or at least the source doesn't indicate this).

The inclusion of incorrect information on non notable (presumably) living individuals related to crimes and convictions is one reason why we have BLP policies and why we shouldn't have articles on such cases unless they are clearly (not borderline) notable, which this case isn't. Fram (talk) 13:43, 14 March 2017 (UTC)


 * Social Legal Studies
 * Canadian Journal of Women and the Law
 * Canadian Journal of Women and the Law


 * Per the above, it does look like this has received some coverage in relevant journals. Weak keep or merge and redirect to Topfreedom in Canada. Timothy Joseph Wood  14:05, 14 March 2017 (UTC)
 * Keep, as per the precedent set in this deletion discussion where it was held that cases reported in legal journals or held as a precedent in later cases were notable. As per the sources in it and those mentioned above, it fulfills that criteria and GNG.  The C of E God Save the Queen!  ( talk ) 14:29, 14 March 2017 (UTC)
 * AfD doesn't work by precedent, and where is the evidence that this case was "held as a precedent in later cases"? The first source, by Valverde, is a truly passing mention similar to the one in her book. From the abstract of the third source given, it is clear that the focus is on R. v. Jacob (which is a notable case) and another case, and not on the Gowan case. So, all in all, these all seem to be passing mentions, not "cases reported in legal journals or held as a precedent in later cases". Fram (talk) 14:43, 14 March 2017 (UTC)
 * Note: This debate has been included in the list of Women-related deletion discussions. Shawn in Montreal (talk) 18:47, 14 March 2017 (UTC)
 * Note: This debate has been included in the list of Law-related deletion discussions. Shawn in Montreal (talk) 18:47, 14 March 2017 (UTC)
 * Note: This debate has been included in the list of Ontario-related deletion discussions. Shawn in Montreal (talk) 18:47, 14 March 2017 (UTC)


 * Keep. This article is about a court case not a person or a criminal act so WP:BLP1E and WP:NCRIME, respectively, do not apply. There are cited reliably-sourced articles from secondary sources (and other uncited material per User:Timothyjosephwood) and the article is not sensational. The existence of the article does not seem, to me, to violate WP:BLP. Edits may be required, and there may be a case for merging, but not deletion Shhhnotsoloud (talk) 13:31, 15 March 2017 (UTC)
 * The case is named after a person (presumably living) not known for anything else, so BLP1E clearly applies. The sources about the case are (apart from one local news article the day of the court decision) simply passing mentions, not one of the sources (in the article or given here) focus on this case or even spend more than one or two sentences on it. The case doesn't meet WP:GNG, and the negative BLP aspects of having this article only add more reason to delete this article. See the WMF resolution on BLPs point 2: "Taking human dignity and respect for personal privacy into account when adding or removing information, especially in articles of ephemeral or marginal interest". This seems to me to be such an article (and the fact that even with such a sensitive subject and such a short article, we can't even get it right, only strengthens the arguments to get rid of it). Fram (talk) 13:53, 15 March 2017 (UTC)
 * I think it probably satisfies WP:NEVENTS:
 * An event that is a precedent or catalyst for something else of lasting significance is likely to be notable. Per the law journal cites, pretty evidently a part of the litany of precedent setting cases related to female toplessness.
 * Notable events usually have significant impact over a wide region Precedent setting for the province of Ontario, i.e., almost half of all Canadians, and apparently an important test of R. v. Jacob, which should probably also have its own article.
 * An event must receive significant or in-depth coverage to be notable. The piece the day of the decision is pretty in-depth. The law cites contextualize the decision as it related to Women's rights in Canada, and demonstrate a lasting social and legal impact. While they may be short in length, they are not routine. Rather, they are experts writing on the topic of toplessness with regard to the law, and covering this among other cases because it is, among other cases, important to an understanding of the subject.
 * It's not the most important court case in the history of the world, but it doesn't have to be. Timothy Joseph Wood  15:12, 15 March 2017 (UTC)
 * I really must be looking at different sources :-) As far as I can tell, not a single court casse has named this one as its precedent, so it's hard to see why you describe this as a "precedent setting case". The "significant impact" for Ontario is reflected in the fact that one newspaper article was written on the decision, and then it was completely forgotten in mainstream journalism and mentioned a very few times in passing in law related articles. What actually was the impact of this "event"? A "lasting social and legal impact"? No evidence for this at all.
 * All your arguments apply to R.v.Jacob, which was a precedent setting case which was the subject of later articles and cases. That is a case, an "event", with lasting impact (still relatively minor, but clearly sufficient for an article if someone wants to write it). But to call the very few one- or two-line mentions of this case since its conclusion "evidence of lasting impact", significance, precedent setting, is really stretching things beyond what's reasonable. Fram (talk) 15:22, 15 March 2017 (UTC)

 Relisted to generate a more thorough discussion and clearer consensus.
 * Personally, I'm in the merge and redirect to "topfreedom in canada" camp. In the scheme of the topic, this is but a mark in the road. Notable enough to merit an inclusion in the article, but not enough to merit an article of its own. This article is little more than a stub, with a mere four sources, and a limited amount to be added which is specific to this particular court decision, as opposed to the broader topic of topfreedom in Canada. But I'm the first to admit I'm no policy expert. As to BLP, it does seem that this decision is public record, and the individual concerned specifically sought that publicity. Again, I emphasize that I have no expertise in BLP matters. Eliyohub (talk) 17:11, 19 March 2017 (UTC)

Please add new comments below this notice. Thanks, Kurykh (talk) 01:14, 22 March 2017 (UTC)
 * Keep. There are some famous cases that were only heard by the trial court, and never appealed. This appears to be one such rare case, not so run of the mill. Bearian (talk) 01:31, 22 March 2017 (UTC)
 * Keep sources seem sufficient, no prejudice against further actions after it is kept (such as merging to other articles), but I see no need to delete outright. -- Jayron 32 04:18, 22 March 2017 (UTC)


 * The above discussion is preserved as an archive of the debate. Please do not modify it. Subsequent comments should be made on the appropriate discussion page (such as the article's talk page or in a deletion review). No further edits should be made to this page.