In Dong v. Boone (Ont CA, 2026) the Ontario Court of Appeal considered R2.1 frivolous and vexatious motion and self-presenters:
[9] As this court noted in P.Y. v. Catholic Children’s Aid Society of Toronto, 2020 ONCA 98, at para. 21:
Although the blunt instrument of r. 2.1.01 should be applied robustly to weed out litigation that is clearly frivolous, vexatious or an abuse of process, the bluntness of the rule and the significant consequences of its application mandate its fair application. Fairness is especially important where the plaintiff is self-represented. [Citations omitted.]
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