In Hart v. Fullarton (Ont CA, 2021) the Court of Appeal considered whether an appeal fell under the RCP R1.03 definition of "proceeding" (it did):
 While it is true that r. 1.03 does not include an appeal within its definition of “proceeding”, this court has held that the language “proceeding … in any court” in s. 140(1)(c) of the CJA includes a proceeding in the Court of Appeal and “proceeding” includes an appeal: Varma v. Rozenberg,  O.J. No. 4183 (C.A.), at para. 5.
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