Is a plaintiff required to lead expert evidence to overcome a no evidence motion?

The defendants further argue that another way of approaching the consideration for expert evidence was stated in Edgar v. British Columbia, supra, at paragraph 7 (relying on Seiler v. Mutual Fire Insurance Co. of British Columbia, supra, at paragraphs 16, 17, and 38): ... where a lay person cannot draw inferences as to the standard of care and causation as a matter of common knowledge, the plaintiff is required to lead expert evidence on such issues in order to overcome a no evidence motion.

As was stated by our Court of Appeal in Roberge v. Huberman at paragraph 56: There may be cases in which the issue as to standard of duty turns so much on the question of "appropriate documentation" that only lawyers practising in the particular field can throw light on the question. Evidence of that kind is undoubtedly useful in some cases, most commonly where the issues involve abstruse questions of conveyancing practice.