What is the test for dismissing an action for non-compliance with a court order?

Master MacLeod noted in Tizard Estate v. Ontario, [2003] O.J. No. 3010: 3 The central question on the motion is whether to impose the drastic remedy of dismissing the claim or to grant some lesser remedy? At what point should delay and disregard for court orders by the plaintiffs (or their counsel) deprive them of the right to proceed with the claim? The answer to that question requires careful review of the substance of the default and its impact on the ability of the court to do justice. Dismissal of an action should not result from trivial technical breaches but should be ordered only when continuation of the action is no longer viable and appropriate. … 21 A secondary but certainly not trivial consideration is the integrity of the justice system. Open disregard for court orders and failure to enforce them with appropriate sanctions will bring the system of case management into disrepute and undermine confidence in the civil justice system. That in a way is to put systemic needs above justice to the individual litigant so again it should be a last resort to be used when a party has by its failure or refusal to be bound by the rules abandoned its right of access to the courts.