What is the test for allowing an unpaid non-lawyer to represent a party at trial?

At the start of trial on November 28, 2017, two Motions were brought by the mother: The first was for the court to interview the child and to have a VCOR prepared during the trial: the second was to permit the mother’s father, who was not a lawyer, to represent her, pursuant to Family Law Rule 4(1) (c) which allows a party to “be represented by a person who is not a lawyer… if the court gives permission in advance.” Following argument, the court reserved its decision with respect to the first Motion until the completion of the parties’ evidence and, in respect to the latter, permission was granted for the maternal grandfather to represent the mother. The father did not object to the mother’s request. In Children’s Aid Society v. P. (D.)[1] Quinn J. held that the test for allowing representation by an unpaid non-lawyer agent-friend did not require a high threshold of “special circumstances” but that, as was proposed in this case, the agent would not be permitted to act as both advocate and witness. As the mother in this case elected not to call her father as a witness, leave was granted to permit him to represent his daughter as her agent for the trial, to examine witnesses and to make closing argument.