What is the test for producing documents under R. 7-1(1) of the Rules of Civil Procedure and Procedure?

British Columbia, Canada


The following excerpt is from Credential Securities Inc. v. Qtrade Canada Inc., 2012 BCSC 1902 (CanLII):

The plaintiffs rely on Biehl v. Strang, 2010 BCSC 1391 para. 16 for the proposition that documents will be producible under R. 7-1(1) where they will advance a party’s case, and, where it was held at para. 29: Rule 7-1 does not restrict production to documents that in themselves prove a material fact. It includes evidence that can assist in proving or disproving a material fact.

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