Can a plaintiff obtain certification to be class counsel?

There, however, is no requirement in the Class Proceedings Act, 1992 that the plaintiff to obtain certification must show some basis in fact that there is a “real and subsisting group who are desirous to having their common complaint determined” and Bellaire v. Independent Order of Foresters is an example of one of those relatively rare cases where Class Counsel trips and stumbles and cannot manage to step over the low hurdle of showing some basis in fact that a common complaint even exists.[20]