What defences have been raised in the reply affidavit or factum in a motion for summary judgment?

As noted the defendants raised, for the first time, certain defences in the reply affidavit or factum. As T. Ducharme J. stated in Caglar v. Moore [2005] O.J. No. 4606, [2005] O.T.C. 935 at para. 14 (S.C.J.): It has long been established that parties to a legal suit are entitled to have a resolution of their differences on the basis of the issues joined in the pleadings. If anything, the importance of proper pleadings is heightened on a motion for summary judgment and the matter should only be resolved as defined in the pleadings. [Citations omitted]