What is the threshold level of relevancy of a question on an examination for discovery?

Canada (Federal), Canada

The following excerpt is from Walsh v. The Queen, 2009 TCC 301 (CanLII):

Respondent's counsel referred to Baxter v. R.[5] for the proposition that the threshold level of relevancy is quite low. In Baxter, the respondent sought an Order compelling the appellant to answer a number of questions which his counsel had instructed him not to answer on discovery. The reason for the objection was that the questions and answers were irrelevant. Bowman A.C.J. (as he then was) made the following comments in respect of relevancy: 12 The principles to be applied in allowing or disallowing questions on examination for discovery are fairly well settled. The threshold level of relevancy is quite low. Counsel should not be inhibited in the questions he or she asks simply because the question may, standing alone, seem irrelevant. The tactics on a discovery vary from counsel to counsel and the style of questioning may simply be a reflection of the counsel's own particular style. …

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