What is the current state of the law on the right of counsel in civil cases?

Canada (Federal), Canada

The following excerpt is from Dadi v. Canada (Minister of Citizenship and Immigration), 1999 CanLII 8560 (FC):

However, the case law states that in general, this right to counsel is not absolute. In Afrane v. M.E.I. (1993), 64 F.T.R. 1, at page 6, Mr. Justice Rothstein wrote:

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