The following excerpt is from Clark v. Retail, Wholesale and Department Store Union,AEL-CIO-CLC, Local 414, 1991 CanLII 6065 (ON LRB):
11. Hence, I indicated to the parties that I would apply the rule of Browne v. Dunn very strictly to any evidence intended to be used or that could be used to impeach the credibility of the complainants and I would require that particular notice had been given to the complainants in cross-examination of any items that could impeach the credibility of the complainants. Absent such particular notice being given to them when they testified, the respondents would be precluded for introducing any such evidence or relying upon any in later argument.
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