What are the requirements for a defendant to set aside a default judgment?

The tests to be applied in an application to set aside a default judgment requires that the defendant show: 1. That he did not wilfully or deliberately fail to enter an appearance or file a defence to the plaintiff’s claim; 2. That he made application to set aside the default judgment as soon as reasonably possible after obtaining knowledge of the default judgment, or give an explanation for any delay in the application being brought; 3. That he has a meritorious defence or at least a defence worthy of investigation; and 4. That the foregoing requirements will be established to the satisfaction of the court through affidavit material filed by or on behalf of the defendant. (Miracle Feeds v. D & H Enterprises Ltd.) [1979] BCJ No. 1965 at para. 5 THE DEFENDANT’S POSITION: