Can a subpoena issued in a civil proceeding be quashed?

Newfoundland and Labrador, Canada


The following excerpt is from Carroll (Re), 2010 NLCA 53 (CanLII):

Re General Hospital Corporation appears to be the only decision in this jurisdiction dealing with the grounds on which a subpoena issued in a civil proceeding may be quashed. In the criminal context, however, Cameron J. in Leahy v. White, 1987 CarswellNfld 325 expressed the view that a subpoena issued under what is now s. 698(1) of the Criminal Code may be quashed:

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