In Grady v. Grady (Ont CA, 2023) the Court of Appeal considered 'proportionality' [under RCP R1.04(1.1)]:
 The application judge did exactly as he was required to do in order to “secure the just, most expeditious and least expensive determination” of these proceedings that was “proportionate to the importance and complexity of the issues, and to the amount involved” here: see rr. 1.04(1) and (1.1) of the Rules of Civil Procedure, R.R.O. 1990, Reg. 194. In keeping with the shift in culture prescribed by the Supreme Court in Hryniak v. Mauldin, 2014 SCC 7,  2 S.C.R. 87, the application judge fairly and justly adjudicated the issues before him without causing the further unnecessary expense and delay that Tracey Ann Grady’s requested adjournment would have occasioned.
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