Is a letter entitled to be without prejudice privileged?

It is established jurisprudence that the words "without prejudice" attached to a letter do not in themselves make it a privileged document to protect it from discovery or from being admitted at trial. It is privileged if it was written for the purpose of expressing the writer's views on the matter in dispute: see Abrams v. Grant (1978), 5 C.P.C. 308.

In Overholt v. Williams, [1958] O.W.N. 422, King J. was of the opinion that neither the master nor the judge in chambers, upon appeal from the master, should refuse leave to amend where to do so it first became necessary to determine difficult matters of fact or of law. All such matters should be left to be determined by the trial judge.