What is the test for hiring a defence counsel in a personal injury case?

Canada (Federal), Canada

The following excerpt is from De Vega v. Canada (Minister of Citizenship and Immigration), 1998 CanLII 9013 (FC):

Now in most instances one does not separate counsel's conduct from that of the client. This may on occasion be harsh, for an innocent client may bear the consequences of hiring counsel who turns out to be less than adequate. This concept is clearly put by Madame Justice Reed in Jouzichin v. MCI, an unreported 9 December 1994 decision in IMM-1686-94, at page 2:

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