Does a learned Master have a right to use the word "instructions" as a privileged word?

Ontario, Canada


The following excerpt is from Currie v. Symcor Inc., 2008 CanLII 37901 (ON SCDC):

Furthermore, the learned Master also held that “instructions” are not privileged, relying on Zielienski v. Gordon, [1982] 1 W.W.R. (B.C.S.C.) at p.417.

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