Churchill v. Unifund Assurance Company

Churchill v. Unifund Assurance Company

The Court granted the stay because the proposed leave issue was not frivolous, the applicant would suffer irreparable harm if compelled to disclose (disclosure cannot be retracted and would render the appeal nugatory), and the balance of convenience favored the applicant since the respondent's harm was limited to...

Source-derived case information.

Citation
2017 NLCA 4
Parties
Applicant: John Churchill; Respondent: Unifund Assurance Company
Court
Newfoundland and Labrador Court of Appeal
Jurisdiction
Canada
Judgment Date
26 January 2017
Procedural Posture
Appeal / Stay Application Pending Leave to Appeal to the Supreme Court of Canada
Outcome
Stay granted
Legal Topics
Stay of Proceedings, Litigation Privilege, Implied Undertaking Rule, Rules of Court Authority, RJR Mac Donald Test
Source Language
en
Civil Procedure Evidence Appellate Practice Privilege Stay of Proceedings Litigation Privilege Implied Undertaking Rule Rules of Court Authority +1 more

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Parties

John Churchill

Applicant

Unifund Assurance Company

Respondent

Procedural Posture

Appeal / Stay Application Pending Leave to Appeal to the Supreme Court of Canada

  1. 1 Whether the Rules of the Supreme Court, 1986 (S.N.L. 1986, c. 42, Schedule D) have legislative authority to override common law litigation privilege and the implied undertaking rule
  2. 2 Whether a stay of the Court of Appeal's January 17, 2017 order should be granted under the RJR MacDonald stay test

Ratio Decidendi

The Court granted the stay because the proposed leave issue was not frivolous, the applicant would suffer irreparable harm if compelled to disclose (disclosure cannot be retracted and would render the appeal nugatory), and the balance of convenience favored the applicant since the respondent's harm was limited to delay and costs which could be remedied; accordingly the stay of the January 17, 2017 order was warranted pending the outcome of the leave application or appeal.

Court Disposition

Stay granted

Orders

  • Stay granted of the Court's January 17, 2017 order requiring listing of documents, answers to Interrogatories and production of medical reports pending the outcome of the applicant's application for leave to appeal to the Supreme Court of Canada or, if leave is granted, pending the appeal
  • No order as to costs