At common law no person may bring an action to trial by commencing an action against himself: see Public Trustee v. Guaranty Trust Co. of Canada, 1980 CanLII 52 (SCC),  2 S.C.R. 931, 115 D.L.R. (3d) 513, 19 C.P.C. 157 (S.C.C.).
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