In Paulpillai Estate v. Yusuf (Ont CA, 2021) the Court of Appeal clarified that the R59 authority to 'amend, set aside or vary' orders focusses on formal orders when made, not on decisions:
 The respondents’ reliance on r. 59.06 is misplaced. The grounds it sets out for re-opening an appeal concern orders, whereas the respondents allege errors in the court’s reasons: Meridian Credit Union v. Baig, 2016 ONCA 942, at para. 6. No order has yet been issued and entered with respect to the court’s decision of October 19, 2020.
 Finality in litigation is important. While the court can reconsider its decision when no order has been taken out and entered, it will only do so sparingly and where the interests of justice would require it to withdraw its reasons and rehear the case on its merits: Meridian Credit, at para.7.
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