Leave to appeal in summary conviction cases granted sparingly

R. v. Janusas, 2011 ONCA 742 has a useful summary of when leave to appeal in summary conviction cases will be granted:

[9]              Before and since the decision of Doherty J.A. in R. v. R.R., [2008] O.J. No. 2468, this Court has only granted leave to appeal in summary conviction cases sparingly.  An appeal to this Court in those circumstances represents a second level of appeal.  Leave is only granted with respect to an error of law and then only when (1) the appeal raises important legal questions having significance to the general administration of criminal justice beyond the particular case, and (2) the merits of the appeal are strong.  Leave may be granted where criterion (1) is met, even where the merits of the appeal may not be particularly strong, though the grounds must be at least arguable.  As well, where the merits are "very strong," leave may be granted even if the issues have not great general significance.  See R.R., at para. 37.