How have courts interpreted the meaning of the word "litigant" in the context of the question?

Canada (Federal), Canada

The following excerpt is from 1772887 Ontario Limited v. M.N.R., 2011 TCC 204 (CanLII):

The Respondent cited Gagnon v. M.N.R., 2006 TCC 66 (CanLII) at paragraph 14 per Bowie J.; affirmed 2007 FCA 33 (CanLII) at paragraph 7 per Létourneau J.

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