In holding as I do, I add as obiter that the distinction between "advice" and "recommendations" can be difficult to describe with clarity. In Samuel Beckett's Waiting for Godot, (New York: Random House, 1954) Estragon would be giving Vladimir "advice" if he said, "Vladimir, I have considered at length the life you lead on this bitch of an earth, and I am of the opinion that you should hang yourself tomorrow." However, Estragon would be providing Vladimir with a "recommendation" if he proposed the following: "Vladimir, I have tested the willow's branch and I am sure that your neck will break before it does. I suggest that you reinforce the branch, find a stepladder so that you can reach it, and proceed with the hanging tomorrow at sundown."
College of Physicians & Surgeons v. British Columbia (Information & Privacy Commissioner)
2001 CarswellBC 1078
British Columbia Supreme Court