In June 2011, the Environmental Review Tribunal released its decision in Currie v. Director (Ministry of the Environment), in which the Tribunal upheld a Ministry of the Environment (M) Director's Order against three individual directors, and applied its reasoning in Kawartha Lakes (City) v. Ontario (Ministry of the Environment). Published in the October 2011 (Vol. 21, No. 1) edition of Environews, the newsletter of the Environmental Law Section of the Ontario Bar Association.