What is the standard for disclosure of documents pursuant to Rule 6(1)(d and 5) of the Rules of Civil Procedure?

It is well-established by case law, and not in dispute on this motion, that the standard for the disclosure of documents pursuant to Rule 6(1)(d) and (5) is that the documents must be arguably relevant to a fact, issue or form of relief sought, or identified by any of the parties. To be arguably relevant, there must be a nexus or rational connection between the document sought to be disclosed and a fact, issue or form of relief sought or identified by the parties (Seeley v. Canadian National Railway, 2013 CHRT 18 (“Seeley”), at para. 6).