908077 ALBERTA LTD (ESCAPE & RELAX) v 1313608 ALBERTA LTD, 2015 ABCA 117

SlatTer JA

2.22: Self-represented litigants

Case Summary

The Respondent, 908077 Alberta Ltd., sought a ruling as to whether the corporate Appellant, 1313608 Alberta Ltd., could be represented on the Appeal by its directors who were not members of the Law Society of Alberta. The underlying litigation arose from a landlord and tenant dispute. The Order under Appeal held that the corporate Appellant could not be represented by its non-lawyer directors. Justice Slatter stated that Rule 2.2 provides that an “individual” may be self-represented in the Superior Courts. The relevant legislation and authorities established that other types of litigants in civil cases, including corporations, must be represented by counsel. Accordingly, Slatter J.A. held that 1313608 Alberta Ltd. was required to obtain counsel, failing which the Appeal would be deemed to be abandoned.

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