When will a court refuse to order production of source documents such as utility bills?

Manitoba, Canada


The following excerpt is from Stonewall & District Lions Manor Inc. v. South Interlake Fifty-Five Plus Inc., 2012 MBQB 86 (CanLII):

I cannot agree with the defendant that the issue is as simple as that. In Grenkow v. Marlatt, (supra), Oliphant A.C.J. declined to order production of source documents, in that case, ledgers and similar documentation used to prepare the plaintiff’s income tax returns. He commented that the requesting parties had failed to articulate to his satisfaction how the production of these source documents would assist them in advancing their case or damaging the plaintiff’s case. In this case, as far as such items as utility bills go, the defendant gave no reason whatsoever to persuade me that the monthly utility bills would prove anything. In addition, I am not satisfied that an adequate rationale has been given for the relevance of source documents in relation to the wages and benefits of the plaintiff’s employees. It may be that relevance of these documents will be established through examinations for discovery, but I am not prepared to order it now.

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