What is the test for relieving a party or counsel of an implied undertaking?

British Columbia, Canada


The following excerpt is from Cochrane v. Heir, 2011 BCSC 477 (CanLII):

In Juman v. Doucette, [2008] 1 S.C.R. 1011, the following is said that governs the exercise of my discretion to relieve a party or counsel of the obligations imposed by the implied undertaking:

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