What is the test for disclosure of material to be disclosed in a civil proceeding?

Canada (Federal), Canada

The following excerpt is from Desson v. Royal Canadian Mounted Police, 2019 CHRT 46 (CanLII):

While the threshold for arguable relevance is low, and the tendency now is toward more disclosure, the nexus between the issues to be proven and the requested material must nonetheless be demonstrated. Warman v. Bahr, 2006 CHRT 18, paras. 6-7, 9.

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