Canada Judgment

Supreme Court of British Columbia

British Columbia (Attorney General) v. Stronks

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01

Holding and result

The AGBC is authorized to seek injunctive relief to prevent a public nuisance that materially burdens court resources and access to justice; the defendant's persistent bulk pseudo-legal communications unreasonably disrupted registry operations and justified a narrowly tailored prohibition that preserves the defendant's ability to file documents by permitted methods.

Court disposition

Application granted

Orders

  • Prohibition: The defendant, Wayne Kelly Stronks, is prohibited from sending correspondence, in any form whatsoever, to the Smithers Courthouse Registry or to any person who works at the Registry.
  • Registry authorization: Registry staff are authorized to disregard and discard any correspondence received contrary to this order.
  • Exception for filing: This order does not apply to any document that the defendant submits for filing into a court file if all the following conditions are met: (i) the document is prepared in accordance with the Rules of Court or a specific direction of the Court; and (ii) the defendant submits the document for filing in person, through Court Services Online, or through an agent.
  • Dispense with signature: The requirement for the defendant's signature on the form of Order is dispensed with.

02

Material facts

Parties

Attorney General of British Columbia

Plaintiff Counsel: M.J. Kleisinger

Wayne Kelly Stronks

Defendant

Amounts and remedies

  • Letters Delivered May3 2023 to Mar27 2024: 1,235
  • Total Correspondence Received by Aug 19 2025 Minimum: 1,500
  • Total Correspondence Received as of Hearing Exceeded: 1,600
  • Average Daily Regular Mail Received by Registry: 5
  • Average Daily Faxes Received by Registry: 5
  • Average Daily Emails Received by Registry: 30

03

Procedural history

  1. Posture

    In Chambers Application for Injunctive Relief by Attorney General / Application Hearing (oral Reasons)

04

Questions and positions

Legal issues

Party arguments

Applicant
AGBC sought an order prohibiting the defendant from sending any correspondence to the Smithers Registry or registry staff because voluminous, nonsensical, pseudo-legal mailings (over 1,600 items) were disrupting registry operations, consuming staff time, risking denial of others' access to justice, and causing concern about potential threats; AGBC relied on s.18.1 Supreme Court Act, s.2(c) Attorney General Act, parens patriae powers and authorities in Randhawa and Andrews, and proposed narrowly tailored restrictions that still permit filing by specified methods.
Respondent
No appearance by the defendant; no submissions or evidence challenging the applicant's affidavit or factual record were presented.

05

Court’s reasoning

  1. 01

    Section 18.1, Supreme Court Act, RSBC 1996, c. 443

    The Attorney General is responsible for provision, operation and maintenance of court facilities and may take reasonable steps to provide a safe, harassment-free environment

  2. 02

    Section 2(c), Attorney General Act, RSBC 1996, c. 22

    The Attorney General superintends matters connected with the administration of justice and may act to protect and defend court integrity

  3. 03

    British Columbia (Attorney General) v. Randhawa, 2024 BCSC 421; In the Matter of Access to the Courts of Justice, 2011 BCSC 1815

    Parens patriae powers permit the AG to seek injunctions to address public nuisances or ongoing breaches of public law affecting court access

  4. 04

    British Columbia (Attorney General) v. Randhawa, 2024 BCSC 421 (para.31, Justice Iyer)

    Restrictive orders affecting access to courts must be exercised sparingly and be tailored to the circumstances to minimally impair access to justice

06

Ratio, limits and disposition

Ratio decidendi

The AGBC is authorized to seek injunctive relief to prevent a public nuisance that materially burdens court resources and access to justice; the defendant's persistent bulk pseudo-legal communications unreasonably disrupted registry operations and justified a narrowly tailored prohibition that preserves the defendant's ability to file documents by permitted methods.

Obiter and limits

  • The defendant did not exhibit the aggressive or confrontational behaviour seen in other cases, but some communications were nonetheless concerning to registry staff
  • Registry staff must open and process incoming mail to protect litigants' access to justice, which makes ignoring mail not a viable option
  • Non-sensical organized pseudo-legal commercial arguments have been consistently rejected by the courts

Court disposition

Application granted

  • Prohibition: The defendant, Wayne Kelly Stronks, is prohibited from sending correspondence, in any form whatsoever, to the Smithers Courthouse Registry or to any person who works at the Registry.
  • Registry authorization: Registry staff are authorized to disregard and discard any correspondence received contrary to this order.
  • Exception for filing: This order does not apply to any document that the defendant submits for filing into a court file if all the following conditions are met: (i) the document is prepared in accordance with the Rules of Court or a specific direction of the Court; and (ii) the defendant submits the document for filing in person, through Court Services Online, or through an agent.
  • Dispense with signature: The requirement for the defendant's signature on the form of Order is dispensed with.

Source and reliance status

Supreme Court of British Columbia · 24 November 2025

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Judgment text

The complete available source text.

Source document

Supreme Court of British Columbia

Judgment· 24 November 2025

2025 BCSC 2579

2025 BCSC 2579 British Columbia (Attorney General) v. Stronks

IN THE SUPREME COURT OF BRITISH COLUMBIA Citation: British Columbia (Attorney General) v. Stronks, 2025 BCSC 2579 Date: 20251124 Docket: S19600 Registry: Smithers Between: Attorney General of British Columbia Plaintiff And Wayne Kelly Stronks Defendant Before: The Honourable Justice Ahmad Oral Reasons for Judgment In Chambers Counsel for the Plaintiff: M.J. Kleisinger Counsel for the Defendant: No appearance Place and Date of Hearing: Smithers, B.C. November 24, 2025 Place and Date of Judgment: Smithers, B.C. November 24, 2025 [1] THE COURT: These reasons were delivered orally. They have been edited for publication. Neither the reasoning nor the outcome have changed. I. Introduction [2] On this application, the Attorney General of British Columbia ("AGBC") seeks an order prohibiting the defendant, Wayne Kelly Stronks from sending correspondence to the Smithers Courthouse Registry ("Registry") or to any person who works there. The order sought does not preclude Mr. Stronks from filing a document in the appropriate form and submitted in person, through Court Services Online, or through an agent. [3] Although served in accordance with an order for substituted service made on October 28, 2025, Mr. Stronks did not appear at this hearing. II. Background Facts and Evidence [4] The primary facts giving rise to this application are set out in the affidavit of Jessica Rysavy, the Manager

of Court Administration for Court Services Branch of the Ministry of Attorney General in Smithers. Among other things, Ms. Rysavy describes Mr. Stronks' escalating conduct in his communications with the Court. [5] In brief, in September 2022, Mr. Stronks began regularly attending the Registry to file various letters, notices, and invoices addressed to justice participants. He continued his attempts to communicate directly with the judiciary despite being informed of the appropriate means by which to do so in accordance with Practice Directive 27. Although generally polite civil and polite on these attendances, his persistence was notable. [6] On September 7, 2022, the Registry began receiving letters from Mr. Stronks which he would typically deliver in person at the Registry counter. While the communications appear "legalistic" in character, they are not in a form contemplated by the Rules nor it is clear from their content what Mr. Stronks wants the Registry to do with them. [7] In May 2023, there was a noticeable change in the content and the method by which Mr. Stronks delivered his communications to the Registry. While all the communications after that date are delivered in their own individual stamped envelope, they are sent in what Ms. Rysavy describes as "bulk mailings", received at the same time - usually nearing or after an event in one of four actions in which Mr.

Stronks is a party. [8] The bulk mailings include several different forms of communications, apparently self-tilted by Mr. Stronks variously as: a Non-Negotiable Notice of Acceptance, a Notice of Dishonor, a Notice of Repentance of Sins for Cause, a Notice of and Rescission of Requisition - General for Cause, and a Certificate of Dishonour. [9] As one example, the content of a "Notice of Repentance of Sins for Cause" received by the Registry on July 4, 2025 includes, in part, the following: PLEASE TAKE NOTICE that I, Wayne Kelly of House Stronks, a sentient moral being, have examined the path my feet are on and have concluded that I have dishonoured many including but not limited to: Supreme Court of British Columbia Smithers Registry, The Honourable Justice [name redacted], Supreme Court of British Columbia Smithers Registry, and others yet to be determined. I am sorry for my errors and THEREFORE, I now REPENT of my sin, As I become aware of additional sins I may have committed, I will repent them immediately. [10] The communications are addressed to numerous people, including judges and judicial officers, registrars, registry staff, and sheriffs. While the meaning or intent of the documents is not clear from their content, the ambiguity in some of Mr. Stronks' communications (e.g., "Dishonor may result for WARRANTS if you fail to respond") has caused concern among some

members of the Registry staff about Mr. Stronks' intended next steps. [11] Between May 3, 2023 and March 27, 2024, Mr. Stronks delivered 1,235 letters to the Registry. Each bulk delivery took Ms. Rysavy anywhere from two hours to three days to review, file, scan, or otherwise deal with - time that she could have been dealing with other members of the public or attending to her other job duties. [12] In response to her written request dated April 3, 2024 to stop sending the letters, Mr. Stronks sent Ms. Rysavy a self-titled "Non-Negotiable Notice of Acceptance", followed by a "Notice of Dishonor", and a "Certificate of Dishonor". He continued to send bulk correspondence to the Registry until May 7, 2024. [13] On June 11, 2024, counsel for the AGBC reiterated the request that Mr. Stronks refrain from sending inappropriate correspondence and advised that if he continued, the AGBC may seek a court order to prevent him from further disrupting registry operations. Counsel expressly advised Mr. Stronks that "[s]uch an order would limit your ability to communicate with the [R]egistry". [14] The Registry did not receive correspondence from Mr. Stronks from then until June 12, 2025 when Mr. Stronks delivered five "Certificates of Dishonor". [15] On June 13, 2025, a lawyer for the AGBC reiterated the request that Mr. Stronks stop corresponding with the Registry and its staff in the manner

he had been doing. [16] Since then, Mr. Stronks has delivered an additional 136 letters to the Registry. To August 19, 2025, the Registry has received over 1,500 written communications from Mr. Stronks. I am told that, as of the date of the hearing of this application, that number exceeds 1,600. [17] Put in context, on average, the Registry receives approximately five pieces of regular mail per day, five items by fax, and 30 emails from members of the public and legal counsel. The volume and nature of the correspondence from Mr. Stronks far exceeds the typical daily volume that the Registry staff is equipped to handle. [18] Ms. Rysavy acknowledges and is concerned with providing everyone, including Mr. Stronks, with access to the court system. She deposes: Registry staff are responsible for opening, reviewing and responding to all mail delivered to the court registry. These items often contain legal documents or inquiries that directly affect individuals' rights and access to justice. The registry is frequently the first point of contact for the public - including self-represented litigants - and it is essential that correspondence is handled promptly and appropriately. Ignoring or discarding mail is not an option, as it may result in missed deadlines, procedural errors, or denial of access to justice. Registry staff are expected to manage all incoming materials diligently in

accordance with operational standards and the CSB commitment to fairness and accessibility. III. Discussion and Analysis [19] Pursuant to s. 18.1 of the Supreme Court Act, RSBC 1996, c. 443, the AGBC is responsible for the provision, operation and maintenance of court facilities, registries, and administrative services. I, accept, as the AGBC submits, that discharging this mandate implicitly requires the AGBC to take reasonable steps to provide a safe environment free of harassment for those working at and visiting the courthouse. [20] Moreover, s. 2(c) of the Attorney General Act, RSBC 1996, c. 22 requires the AGBC to superintend all matters connected with the administration of justice in British Columbia. Protecting and defending the integrity of all levels of court in the province falls squarely within these functions: British Columbia (Attorney General) v. Randhawa, 2024 BCSC 421 at para. 28. [21] Finally, the AGBC's parens patriae powers authorize her to seek injunctions where there is a public nuisance or an ongoing breach of the public law: Randhawa at para. 28, citing In the Matter of Access to the Courts of Justice, 2011 BCSC 1815 at paras. 3-4. [22] I am satisfied that the above authorities allow the AGBC to seek the orders sought. I am also satisfied that this Court has the authority to grant them: Randhawa at para. 29, citing British Columbia (Attorney General) v.

Andrews, 2016 BCCA 361 at paras. 17 - 18. [23] However, limits should be placed on any orders granted. As Justice Iyer (then of this Court) notes in Randhawa: [31] In my respectful opinion, while the AG has the authority to bring applications such as this and the court has the power to grant them, they should be exercised sparingly, reserved for those comparatively rare cases where lesser measures are demonstrably ineffective. The right of all individuals to access the courts is fundamental and should be restricted as little as possible. However, where a person's exercise of their right of access directly or indirectly diminishes those of others and places unreasonable burdens upon court resources, restrictions are justified. They should be tailored to respond to the particular circumstances of the case. [24] I am satisfied that it is appropriate in the circumstances of this case to grant the orders sought. [25] In reaching that conclusion, I acknowledge that Mr. Stronks has not directly exhibited the "aggressive and threatening" or "confrontational" behaviour that resulted in the interim injunctive relief circumscribing the basis on which Mr. Randhawa was able to enter British Columbia courthouses. However, the content of some of Mr. Stronks' communications appears threatening or, at least, concerning. The views expressed by some members of the Registry staff in that regard is

warranted. [26] It is also significant that none of the communications have any legitimate legal purpose and do nothing to legitimately advance Mr. Stronks' position in any court process. As counsel for the AGBC suggests, the non-sensical nature of the communications is very much akin to the types of organized pseudo-legal commercial arguments consistently rejected by the Courts. [27] The time required by the Registry to handle the volume, and to attempt to decipher the content, of Mr. Stronks' communications detracts from its ability to attend to other members of the public who do comply with the legal process, some of whom rely on the Registry staff for guidance in navigating the court system. That guidance, only a part of the Registry staff's important work, ensures that self-represented litigants can access the court system effectively and fairly. [28] The burden on court resources caused by Mr. Stronks' conduct is clear. The fact that Mr. Stronks continues to send voluminous correspondence despite written requests that he refrain from doing so highlights his disregard for the disruption he continues to cause. [29] I am satisfied that the injunctive relief sought is necessary to protect the public interest in equitable access to the justice system and to address the public nuisance caused by Mr. Stronks' conduct. [30] I am also satisfied that the orders sought will only

minimally restrict Mr. Stronks' right to access the courts. In particular, allowing Mr. Stronks to file documents in accordance with the Rules or direction of the Court, as contemplated, will not deprive Mr. Stronks of the ability to litigate in British Columbia, including by taking steps in the actions in which he is currently involved. While the form of order will restrict the way he can file documents (i.e., not by mail), he is not precluded from filing appropriate documents all at. In fact, three options (in person, through Court Services Online, or through an agent) will remain available to him. [31] With those express allowances, Mr. Stronks will not be deprived of access to justice or the ability to maintain or defend a claim in court. I am satisfied that the orders sought are appropriate and they will be granted. IV. Disposition [32] To summarize, I make the following orders: a) An order prohibiting Mr. Stronks from sending correspondence, in any form whatsoever, to the Registry, or to any person who works at the Registry; b) The Registry staff is authorized to disregard and discard any correspondence received contrary to this order; c) This order does not apply to any document that Mr. Stronks submits for filing into a court file if all the following conditions are present: i. the document is prepared in accordance with: (1) the Rules of Court; or (2) a specific

direction of the Court; and ii. Mr. Stronks submits the document for filing: (1) in person; or (2) through Court Services Online; or (3) through an agent. [33] So there is no uncertainty, I also make an order dispensing with the requirement for Mr. Stronks' signature on the form of Order. [34] Thank you to counsel for his thorough review of the facts and the law giving rise to this application, for which I am grateful. "Ahmad J."

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

British Columbia (Attorney General) v. Randhawa, 2024 BCSC 421

Case cited

British Columbia (Attorney General) v. Andrews, 2016 BCCA 361

Case cited

In the Matter of Access to the Courts of Justice, 2011 BCSC 1815

Case cited

Supreme Court Act, RSBC 1996, c. 443 s.18.1

Legislation

Legislation referenced in the available case record.

Attorney General Act, RSBC 1996, c. 22 s.2(c)

Legislation

Legislation referenced in the available case record.

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