This Decision addressed the purported representation of a litigant by an individual not qualified under the Legal Professions Act, RSA 2000, c L-8. Among other things, the individual argued that he was permitted to, and did, appear as a “McKenzie friend”, as described in the case of McKenzie v McKenzie, [1970] 3 All ER 1034 (UK CA) (“McKenzie”).

The Court held that the McKenzie friend concept is codified in Alberta in Rule 2.23, such that the role is limited to quiet suggestions, note-taking, support, or addressing the particular needs of a party. Neither Rule 2.23 nor McKenzie permit representation by non-lawyers in the Court of King’s Bench. For this reason and others, the individual was prohibited from further participation in the litigation, and from representing or providing legal assistance in other Court of King's Bench proceedings.