What is the current state of the law on “indifference” in the context of the Gronnerud decision?

On the motion before me much of the dispute between the parties turned on a proper understanding of this portion of the Gronnerud decision. Does the concept of “indifference” go further than the Ontario courts’ traditional approach to the notion of conflict of interest, or is it simply a variation on a theme? I agree with the conclusion expressed by Morawetz J. in Shemesh v. Goldlist (unreported, April 3, 2008) where he observed, at paragraph 26, that “there is no significant difference between the “indifference” approach and the “conflict of interest” approach.” Both terms, in my view, describe a common concern – will the proposed litigation guardian be able to put aside his own interests and represent the dependant person in the litigation in a manner that will promote that person’s best interests?