What is the test for using the term "any non-judicial body" in a reference to vexatious litigant proceedings?

Alberta, Canada


The following excerpt is from Makis v Alberta Health Services, 2020 ABCA 168 (CanLII):

At a threshold level, it is clear the use of the term “any non-judicial body” was unacceptably broad and imprecise. A breach of a vexatious litigant order is a contempt of court, which may result in severe sanctions. Any person subject to such an order is entitled to know exactly what conduct is prohibited: Gurtins v. Panton-Goyert, 2008 BCCA 196 at paras. 14-16, 81 BCLR (4th) 81.

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