T-3587-77 
CC Chemicals Limited (Plaintiff) 
v. 
Sternson Limited (Defendant) 
Trial Division, Cattanach J.—Ottawa, June 19 
and August 1, 1980. 
Practice — Discovery — Motion to restrain defendant from 
proceeding with examination for discovery of inventor/assignor 
residing in the U.S. — Ex parte application seeking order to 
compel said inventor to submit to a discovery deposition 
granted to defendant by foreign Court Claim by plaintiff 
that procedure is inappropriate without motion for directions 
made to Federal Court — Whether authority to grant order 
compelling assignor of a patent not resident in Canada to 
attend to be examined for discovery either within or outside 
Canada — Federal Court Rules 465(5),(12),(16), 494(9) — 
Canada Evidence Act, R.S.C. 1970, c. E-10, s. 43. 
Plaintiff moves for an order restraining the defendant from 
proceeding with an examination for the discovery of the inven
tor and initial assignor of a patent of invention who is residing 
in the United States, otherwise than in accordance with the 
Rules of this Court. Defendant, who relied on Rule 465(5) 
without result, sought and was granted, by a United States 
District Court, an ex parte application without letters rogatory 
from this Court for an order directing the inventor to submit to 
a discovery deposition upon oral examination in accordance 
with the Rules of the foreign Court. Plaintiff claims that 
defendant's course of action in relation to the action in this 
Court is inappropriate without the procedure to do so first 
being settled in a motion for directions made to this Court, and 
is contrary to the law of this country. The question is whether 
there is authority for the grant of an order whereby the 
assignor of a patent who is not resident in Canada can be 
compelled to attend to be examined for discovery either within 
or outside Canada. 
Held, the application is allowed. (1) It is inappropriate for 
the defendant to obtain an order from a foreign court to compel 
the attendance of an assignor of an invention resident within 
that jurisdiction for examination in relation to an action in this 
Court without first seeking such process as is available to it: a 
particular court is the master of its own procedure and of the 
conduct of proceedings before it in conformity with the general 
law applicable and its Rules. (2) Rule 465(5) cannot operate 
where the person to be examined is outside Canada and cannot 
be made the subject of a subpoena issued out of a Canadian 
Court (per Jackett C.J. in the Lido case). Such an order cannot 
be made because the Court by its own process, cannot enforce 
its order: the Rules of the Federal Court do not contemplate it. 
Resort may not be had to the issuance of a commission to 
examine for discovery the assignor of a patent to be conducted 
outside Canada; neither may Letters rogatory nor letters of 
request be utilized to achieve that end. The purpose of these 
letters is to take evidence out of the jurisdiction for use as 
testimony in the action within the jurisdiction. There is no 
doubt that defendant was not seeking the assignor's testimony, 
but rather information and a train of inquiry. The Court will 
restrain a litigant before it from prosecuting proceedings in a 
foreign court for the purpose of searching out evidence or 
information respecting an action in the Court which proceed
ings in the foreign court are not permissible under its Rules. 
The defendant can obtain no "legitimate advantage". 
Lido Industrial Products Ltd. v. Teledyne Industries, Inc. 
[1979] 1 F.C. 310, applied. Lovell Manufacturing Co. v. 
Beatty Bros. Ltd. (1961) 35 C.P.R. 12, applied. Textron 
Canada Ltd. v. Rodi & Wienenberger AG [1973] F.C. 
667, applied. Xerox of Canada Ltd. v. IBM Canada Ltd., 
IBM Canada Ltée [1976] 1 F.C. 213, applied. Dennison 
Manufacturing Co. of Canada Ltd. v. Dymo of Canada 
Ltd. (1976) 23 C.P.R. (2d) 155, applied. The Carron Iron 
Co. Proprietors v. Maclaren (1854-56) 5 H.L., Cas. 416, 
applied. Armstrong v. Armstrong [1892] P. 98, applied. 
Re Raychem Corp. v. Canusa Coating Systems, Inc. 
[1971] 1 O.R. 192, considered. 
MOTION. 
COUNSEL: 
D. MacOdrum for plaintiff. 
J. Morrissey for defendant. 
SOLICITORS: 
Hayhurst, Dale & Deeth, Toronto, for 
plaintiff. 
Barrigar & Oyen, Ottawa, for defendant. 
The following are the reasons for judgment 
rendered in English by 
CATTANACH J.: The plaintiff moved by notice 
dated June 16, 1980, which application was heard 
on June 19, 1980, for an order restraining the 
defendant from proceeding with an examination 
for the discovery of Solomon J. Rehmar in relation 
to this action as assignor of a patent of invention 
otherwise than in accordance with the Rules of 
this Court. 
As the examination was to take place within 
three juridical days I gave the order requested at 
the conclusion of the hearing of the application but 
undertook to give written reasons for so doing. 
These reasons are in discharge of that 
undertaking. 
The plaintiff is a company incorporated pursu
ant to the laws of the Province of Ontario with 
head office at Thornhill, Ontario. As such it is 
therefore resident and domiciled in Canada. 
The defendant is also a company incorporated 
pursuant to the laws of the Province of Ontario 
with head office in Brantford, Ontario and is 
likewise resident and domiciled in Canada. 
The plaintiff is owner of a patent of invention 
issued by the Patent Office of Canada on October 
17, 1967 to Solomon J. Rehmar, of Cleveland, 
Ohio, one of the States of the United States of 
America with respect to an invention by him. 
Rehmar by assignment dated October 27, 1969 
and recorded on November 21, 1969 transferred 
his rights in that patent to Intrusion Prepakt In
corporated, a company incorporated under the 
laws of the State of Ohio. 
By assignment dated September 16, 1969 Intru
sion Prepakt Incorporated transferred the patent 
to the plaintiff. 
By statement of claim dated September 23, 
1977 and filed in this Court on that date the 
plaintiff alleges that the defendant has infringed 
the plaintiff's exclusive rights under that patent 
and seeks the usual relief. 
The defendant has filed a statement of defence 
which basically alleges that no invention is 
described in the claims, denies infringement and 
alleges the invalidity of the patent. These are 
standard defences to an action for infringement. 
The allegations are supported by particulars. 
By letter dated October 15, 1979 the solicitors 
for the defendant inquired of the solicitors for the 
plaintiff as to the invention date to be relied upon 
which elicited the reply that the invention date 
being relied upon was April 4, 1979. 
By letter dated September 28, 1978 the solici
tors for the defendant notified the solicitors for the 
plaintiff of their intention to examine for discovery 
Solomon J. Rehmar as inventor and an officer of 
Intrusion Prepakt Incorporated both as assignors. 
By letter dated October 30, 1978 in reply the 
solicitors for the plaintiff pointed out that both 
assignors were resident outside of Canada, that 
they represented neither of these parties and that 
the Rule upon which the defendant proposed to 
rely did not extend to the examination of these 
parties out of the country. 
The Rule upon which the defendant proposed to 
rely was identified in a letter dated October 15, 
1979 as Rule 465(5). 
The plaintiff made available for discovery its 
president. 
On April 24, 1980 the defendant advised that 
the steps required would be taken to secure the 
examination of Rehmar before trial. 
The plaintiff reiterated that the Rules did not 
permit of the examination of a non-party to the 
litigation who is not resident in Canada particular
ly a retired inventor who is not under the control 
of the plaintiff. 
Mr. Rehmar is over 87 years of age and has 
indicated that he would not willingly submit to 
examination for discovery. He is not and never was 
an employee of the plaintiff and the plaintiff has 
no control whatsoever over him. 
Apparently there was a telephone conversation 
between the solicitors which prompted the plain
tiff's solicitors' letter dated May 22, 1980 and a 
reply thereto dated June 4, 1980 which I consider 
expedient to reproduce as demonstrative of the 
dispute between them. 
The plaintiff's solicitors wrote: 
We have considered the information given to us by you in 
your telephone call of May 18, 1980 that you intend to seek the 
discovery of Mr. Rehmar, the inventor named in the patent in 
suit in the Federal Court, which currently has jurisdiction over 
the subject matter of the dispute between our respective clients. 
It appears that you recognize that the Rules of the Federal 
Court, and the decisions made under those Rules, do not permit 
you to obtain the examination for discovery of Mr. Rehmar. It 
further appears to us that you are attempting to by-pass those 
Rules, and indeed to by-pass the Federal Court entirely, despite 
the fact that this action is to be governed by the Rules of 
practice in the Federal Court. It is our concern that your 
proposed activities may be considered contemptuous of the 
Federal Court, and we are not sure of the extent to which we 
should become involved in those activities. 
There are a number of questions that arise out of this 
proposed procedure, and it is our view that these should be 
settled on an application for directions to the Federal Court. 
First of all, is it appropriate that Mr. Rehmar be examined, 
having regard to the practice of the Federal Court? If Mr. 
Rehmar is to give commission evidence, can you establish that 
he has refused to appear at the trial of this action? If Mr. 
Rehmar is giving commission evidence pursuant to your 
request, are you producing Mr. Rehmar as your witness, and 
are we to be entitled to cross-examine Mr. Rehmar? If you are 
to take commission evidence of Mr. Rehmar, should not the 
whole of Mr. Rehmar's evidence be read into the proceedings at 
the trial of the action, or are you to be entitled to read in those 
portions only which are, in your view, favourable to your case? 
As it is our view that your proposed procedure is a clear 
attempt to by-pass Rules of the Federal Court, I would suggest 
that you bring your application for directions forthwith. If you 
do not bring this application, we shall bring our own applica
tion. We see no reason why we should be put to the trouble and 
expense of proceeding with a deposition of Mr. Rehmar when 
the Rules do not provide for his discovery, and there is further
more no evidence that he has been requested, and has refused, 
to appcar at the trial of this action. 
The solicitors for the defendant replied: 
Your letter of 22 May 1980 was received in our office on 29 
May 1980. 
If you wish to apply to the Federal Court of Canada for 
directions in respect of our proposal to obtain Mr. Rehmar's 
deposition then please do so. 
In our opinion, our proposed course of action for obtaining 
evidence from Mr. Rehmar is not, in any way, contemptuous of 
the Federal Court of Canada. Rather, we wish to obtain Mr. 
Rehmar's testimony in order that we may have evidence from 
the inventor before proceeding to the trial of this action. 
In your letter you have stated, "We see no reason why we 
should be put to the trouble and expense of proceeding with a 
deposition of Mr. Rehmar when the Rules do not provide for 
his discovery, and there is furthermore no evidence that he has 
been requested, and has refused, to appear at the trial of this 
action.". On the contrary, Federal Court Rule 465(5) does 
provide for the discovery of Mr. Rehmar. "The assignor of a 
patent of invention, copyright, trade mark, industrial design or 
any property, right or interest may be examined for discovery 
by any party who is adverse to an assignee thereof." (Where 
the context so permits, a reference in this Rule to an individual 
to be questioned or to the individual being questioned includes 
such an assignor.) You have refused consistently to volunteer 
Mr. Rehmar for discovery pursuant to Rule 465(5) and, by 
virtue of your actions, have left us with no option but to apply 
to the appropriate United States court of competent jurisdic
tion. If Mr. Rehmar were a Canadian resident then there would 
be no difficulty whatsoever in obtaining his testimony. Instead, 
you have relied upon the technical ground that Mr. Rehmar is 
a United States resident so as to avoid making him available to 
us for discovery. 
After reviewing the discovery of Mr. Rehmar, we shall 
consider what further steps, if any, are required. 
Lastly, we note that this is not the first time that the 
pertinent United States statute has been invoked by litigants 
involved in proceedings before the Federal Court of Canada. 
With respect to the concluding paragraph at the 
hearing of the application I asked the solicitor for 
the defendant to point out to me the instances to 
which he referred, what prior request had been 
made to this Court, and if no prior authorization 
had been so requested and obtained such as by 
way of letters rogatory or a letter of request, was 
any evidence so obtained admitted as evidence at 
the trial of the action in this Court. 
He could not do so. What he meant was that on 
three occasions of which he was aware application 
had been made to courts in one or other of the 
States of the United States to compel a resident to 
appear and give evidence independently of any 
intercession by this Court but that any evidence so 
obtained was apparently not tendered for use as 
evidence in a trial of an action before this Court. 
Thus I am left without precedent in this Court 
which I had fully suspected to be the case. 
I expressed the view that it was not within my 
jurisdiction to interfere with what a foreign court 
may do under the laws which it may administer 
and apply. Certainly I have no power to do that. It 
was my initial reaction that the matter might best 
be left to the Trial Judge to decide the admissibili
ty of evidence so obtained if tendered at trial as 
evidence but the order sought by the plaintiff as 
applicant herein goes far beyond that. 
The suggestion was made by the plaintiff that 
for the defendant to seek an order from a foreign 
court to compel the attendance of the inventor for 
examination in relation to the action in this Court 
was most inappropriate without the procedure to 
do so contemplated first being settled on a motion 
for directions made to this Court. 
Frankly the logic of that suggestion has com
mended itself to me but apparently not to the 
solicitor for the defendant who blithely ignored the 
suggestion so made and initiated a unilateral 
application to a judge of the United States District 
Court for the Northern District of Ohio, pursuant 
to 28 U.S.C. § 1782 for an order directing the 
issuance of a subpoena duces tecum commanding 
Solomon J. Rehmar to attend and "submit to a 
discovery deposition to be taken by Sternson upon 
oral examination for use in a proceeding now 
pending before the Federal Court of Canada, Trial 
Division". 
The applicant, Sternson, requested that it be 
ordered that "the testimony shall be taken in 
accordance with the Federal Rules of Civil Proce
dure". This I take to be Rules applicable in the 
foreign jurisdiction because such expression is 
unknown in this jurisdiction. 
The title to and substantive part of paragraph 
1782 (which in all likelihood might be a federal 
statute) reads: 
§ 1782. Assistance to foreign and international tribunals and to 
litigants before such tribunals 
(a) The district court of the district in which a person resides 
or is found may order him to give his testimony or statement or 
to produce a document or other thing for use in a proceeding in 
a foreign or international tribunal. The order may be made 
pursuant to a letter rogatory issued, or request made, by a 
foreign or international tribunal or upon the application of any 
interested person and may direct that the testimony or state
ment be given, or the document or other thing be produced, 
before a person appointed by the court. 
The ex parte application which is undated but 
appears to have been filed in the foreign court on 
June 10, 1980 was apparently heard on that day 
by the judge of that court who endorsed the 
margin of the application: "The motion is granted. 
It is so ordered. Frank J. Battisti". I assume that 
the grant of such an order is not mandatory but 
discretionary. 
The application was made without notice to the 
party adverse in interest and it was unfortunate 
that the learned Judge was deprived of the advan
tage of hearing representations contrary to the 
grant thereof. Basically the representation vigor
ously advanced before me was that there is no 
authority for the grant of an order whereby the 
assignor of a patent who is not resident in Canada 
can be compelled to attend to be examined for 
discovery either within or outside Canada and to 
do so is contrary to the law of this country. 
The former Chief Justice of this Court had 
occasion to consider this question in Lido Indus
trial Products Ltd. v. Teledyne Industries, Inc. 
[1979]1 F.C. 310 when he delivered the judgment 
of the Appeal Division. 
The Trial Division had dismissed an application 
for an order to produce the assignor of a patent 
resident in the United States to be examined for 
discovery pursuant to Rule 465(5). That decision 
was appealed. 
Jackett C.J. dismissed the appeal because there 
is no authority for the order sought. None had 
been referred to and he knew of none. 
Having so stated he considered it expedient to 
explain why the application for that order was not 
only misconceived but was an attempt to obtain 
relief that is not available under the Rules. 
He pointed out at pages 311 and 312: 
As I understand it, examination for discovery, as commonly 
understood, is a pre-trial process whereby one party to an 
action obtains information or admissions from the other and is 
one of the few aspects of our procedure that has no root in the 
procedure of the United Kingdom. It is now almost universally 
found in superior courts in Canada but, in each court, is a 
product of the relevant statute and the Rules made thereunder. 
The relevant Rule is Rule 465 of the Federal 
Court Rules made under section 46 of the Federal 
Court Act, R.S.C. 1970 (2nd Supp.), c. 10. 
The Chief Justice explained that no order of the 
Court is required for an examination for discovery 
except in exceptional circumstances. 
The simplest case is in an action of one individu
al against another where one party examines 
another (Rule 465(1),(2) and (3)). In such a case 
no order of the Court is contemplated unless it is 
required to nominate an examiner (Rule 
465(6)(c)). 
The sanction against a party which fails to 
submit to discovery or answer questions required 
by the Court is, if a defendant, to have the defence 
struck out, or, if a plaintiff, to have the action 
dismissed. 
The second exception is an examination for 
discovery of the Crown or a corporation. In the 
event that the parties cannot agree on the officer 
to be questioned then an order of the Court may 
be sought to nominate an officer (Rule 465(1)(b), 
(c)). 
Under Rule 465(12) it is possible that an exami
nation for discovery may, in certain circumstances, 
be held outside Canada but only by an agreement 
or with authority of an order of the Court. This is 
the third exception to the general rule that no 
order of the Court is necessary for arranging for 
commencement of an examination for discovery. 
Rule 465(5) reads: 
Rule 465. .. . 
(5) The assignor of a patent of invention, copyright, trade 
mark, industrial design or any property, right or interest may 
be examined for discovery by any party who is adverse to an 
assignee thereof. (Where the context so permits, a reference in 
this rule to an individual to be questioned or to an individual 
being questioned includes such an assignor). 
In commenting upon this somewhat unusual 
provision the Chief Justice had this to say at pages 
313 and 314: 
Rule 465 also includes provision (Rule 465(5)) for something 
that is called an examination for discovery but that does not fall 
within what is ordinarily thought of as an examination for 
discovery of one party by another; it is a pre-trial questioning of 
a potential witness, and the only person who can be questioned 
thereunder is the assignor of the property right that is the 
subject of the litigation, who is subject to being questioned 
whether or not he is an officer or other employee of the 
opposing party. 
The mode of enforcing attendance for examination of a 
person subject to questioning by virtue of Rule 465(5) is a 
subpoena (Rule 465(9)); as such a person is not necessarily 
under the control of the opposing party, that party does not 
become subject to having his defence struck out or to having his 
action dismissed by reason of such person failing to attend and 
answer as required. (Rule 465(20).) Presumably, Rule 465(12) 
contemplates the Court authorizing such an examination taking 
place outside Canada but one does not find anything in the 
Rules authorizing the Court to order such a person to appear 
for examination inside or outside Canada; and any such author
ity would not be expected having regard to the provision for a 
subpoena in Canada and the Court's inability to issue orders or 
other process having effect outside its geographical jurisdiction 
(see McGuire v. McGuire [1953] O.R. 328). In other words, 
there is an implied limitation, as far as Rule 465 is concerned, 
on the ambit of Rule 465(5) in that it cannot operate where the 
person to be examined is outside Canada and cannot be made 
the subject of a subpoena issued out of a Canadian court. This 
is not to say that there may not be an international convention 
between Canada and another country, duly implemented by 
statute in both countries, that would authorize such examina
tions. I do not recall any such convention that contemplates 
pre-trial examination of potential witnesses as opposed to 
obtaining evidence in one country for use at trial in another 
country. 
I have said so much in this connection not only to make it 
clear that, in my view, the appellant is not failing to obtain 
what he seeks merely because he frames his application inade
quately, but also to make it clear that, in my view, he sought 
something that the Rules did not, and could not, give him any 
right to obtain. I also have attempted to bring out that there 
seems to be a tendency to seek from the Court orders concern
ing the details of launching an examination for discovery 
(person to be examined, place, time, etc.) that should not be 
taking up the time of the Court when the Rules do not provide 
for them. 
In argument before me counsel for the defend
ant suggested that if the Chief Justice had been 
aware of paragraph 1782 of the United States 
Code he would have decided other than he did. 
He predicated this submission on the particular 
language in the extract quoted which reads: 
This is not to say that there may not be an international 
convention between Canada and another country, duly imple
mented by statute in both countries, that would authorize such 
examinations. I do not recall any such convention that contem
plates pre-trial examination of potential witnesses as opposed to 
obtaining evidence in one country for use at trial in another 
country. 
When the Chief Justice referred to an interna
tional convention implemented into the domestic 
law of each contracting state by statute he meant 
precisely what he said. 
He did not mean a domestic statutory law as 
paragraph 1782 of the United States Code appears 
to be. He meant, as he said, mutually reciprocal 
statutes enacted by the respective States to an 
international convention by which the terms of the 
convention agreed upon become part of the law of 
each State which was party to the convention. 
There is no indication that paragraph 1782 is such 
a statute. 
In so contending counsel must be drawing an 
analogy between a law of a foreign State as such 
and a law of a foreign State enacted to meet 
obligations incurred by being signatory to an inter
national convention. No such analogy exists. 
Counsel for the defendant did not refer me to 
such a convention no doubt because no such con
vention exists. I should add that I have made a 
search for such a convention without avail. 
Jackett C.J. has stated that there is an implicit 
limitation on the ambit of Rule 465(5) in that it 
cannot operate where the person to be examined 
for discovery is outside Canada. 
Resort may not be had to a commission to take 
evidence to conduct an examination for discovery 
of the assignor of a patent of invention who is 
resident outside Canada. 
Cameron J. in Lovell Manufacturing Co. v. 
Beatty Bros. Ltd. (1961) 35 C.P.R. 12 said [at 
page 13]: 
In my view, Rule 129 does not authorize the Court to issue a 
Commission to examine for discovery an assignor of any patent 
of invention (who, in this case, is not a party in the action) 
outside of Canada. 
In Textron Canada Ltd. v. Rodi & Wienenberg-
er AG [1973] F.C. 667 Kerr J. held that orders for 
commissions to examine assignors of a patent resi
dent in Germany and Japan could not be made 
under Rule 477, that is by commission evidence. 
Rule 477 of the Federal Court Rules is the succes
sor to Rule 129 of the Exchequer Court Rules 
referred to by Cameron J. 
However he did entertain the possibility of an 
order for discovery under Rule 465(12) analogous 
to the kind of order contemplated in Rule 477 on 
being satisfied that there were conventions or trea
ties between Canada and Germany and Japan 
under which the examinations applied for would be 
held in or permitted by the laws of those countries. 
He therefore reserved the motion for one month in 
order that counsel for the parties might so inquire. 
Apparently the Textron case was settled shortly 
after the judgment of Kerr J. was delivered and 
accordingly the application was not pursued. 
In Xerox of Canada Ltd. v. IBM Canada Ltd., 
IBM Canada Ltée [1976] 1 F.C. 213 it was moved 
by the defendant before Heald J. for orders 
authorizing the issuance of letters rogatory to 
permit the examinations for discovery of eighteen 
inventors and assignors of patents residing in five 
different jurisdictions in the United States. In so 
applying the defendant relied on paragraphs (5) 
and (12) of Rule 465 and the remarks of Kerr J. in 
the Textron case (supra) that is that if he could be 
satisfied that an order would be effective under the 
laws of the country where the request is to be 
executed he would then consider an application to 
that end. 
In support of the application before Heald J. the 
defendant submitted affidavits of a qualified attor
ney from each of the jurisdictions of New York, 
Connecticut and two districts in California to the 
effect that the courts in these jurisdictions would 
execute letters of request from this Court to enable 
the defendant to obtain examination for discovery 
of the assignors of a patent resident in these 
jurisdictions. 
In response the plaintiffs filed affidavits of 
equally qualified attorneys whose opinions were 
diametrically opposite. The firm view was 
expressed that the California courts would not act 
upon such letters of request because the evidence 
so obtained could not be introduced as evidence in 
the action but could only be used for the purpose 
of gaining information. This may not be necessari
ly so. 
The deponents of the rebuttal affidavits were 
clearly of the view that the courts of Connecticut 
and New York would not act on letters rogatory or 
letters of request of this Court because of the 
inability of the Federal Court of Canada to recip
rocate under the laws of this country. The inability 
to reciprocate has been held to exist. 
Under section 43 of the Canada Evidence Act, 
R.S.C. 1970, c. E-10, a Canadian court may, in its 
discretion, order the attendance in Canada of a 
party or witness within its jurisdiction where it 
appears that a foreign court of competent jurisdic
tion is desirous of obtaining the "testimony" of 
such witness in relation to a matter pending in the 
foreign Court. 
Section 60 of The Evidence Act of Ontario is to 
like effect. 
In Re Raychem Corp. v. Canusa Coating Sys
tems, Inc. [1971] 1 O.R. 192, Brooke J.A. said at 
page 197: 
It is the law of this Province that whether one proceeds under 
the relevant provisions of the Ontario Evidence Act, R.S.O. 
1960, c. 125, or the Canada Evidence Act, R.S.C. 1952, c. 307, 
the Court will order an examination of a witness only if it is 
clear that what is intended is the taking of that evidence for the 
purpose of trial. No such order will be made if the principal 
purpose is to use such proceedings to search out evidence and 
information in the same way as on examination for discovery. 
In Re Radio Corp. of America v. Rauland Corp. et al., [1956] 
O.R. 630 at p. 635, 5 D.L.R. (2d) 424 at p. 428, 26 C.P.R. 29, 
Gale, J., as he then was, adopted the language of Devlin, J., in 
Radio Corp. of America v. Rauland Corp. et al., [1956] 1 Q.B. 
618 at p. 646, when he said: 
Testimony which is in the nature of proof for the purpose of 
the trial is permissible. Testimony, if it can be called "tes-
timony," which consists of mere answers to questions on the 
discovery proceeding designed to lead to a train of inquiry, is 
not permissible. 
Incidentally I was prompted by the use of the 
word "testimony" in paragraph 1782 of the United 
States Code to refer to definition of that word in 
Black's Law Dictionary, 5th ed., since that work is 
definitions of words and phrases of American and 
English jurisprudence. 
Testimony is therein defined as properly 
meaning: 
... only such evidence as is delivered by a witness on the trial 
of a cause, either orally or in the form of affidavits or 
depositions. 
Before Mr. Justice Heald the motions sought 
were opposed on a twofold basis. 
The first submission was that this Court has no 
jurisdiction under any circumstances to issue let
ters rogatory to a foreign court. 
Heald J., because of the disposition he made of 
the motion did not elaborate on the exact nature of 
that submission or the reasons advanced in its 
support. Conceivably, and I speculate, it may have 
been that jurisdiction is lacking in the absence of 
an international convention or treaty implemented 
by statute in the contracting States that would 
authorize examinations of the nature sought or 
perhaps that there is no authority in the Federal 
Court Act and Rules made thereunder. 
The second basis advanced was that "even if this 
Court does have the power to issue letters rogato-
ry, that power is discretionary and should not be 
exercised to order the examination for discovery of 
an assignor who is not a party to the action". This 
quotation is extracted from Mr. Justice Heald's 
reasons for judgment at page 217. Being extracted 
from its whole context and in the light of Rule 
465(5) I would assume it might be proper to add 
at the conclusion of the quotation words such as 
"resident out of the jurisdiction and as directed to 
be conducted by the court of the jurisdiction in 
which the assignor resides". 
Heald J. did state that the discretion should not 
be exercised because no reciprocity exists in the 
Federal Court of Canada and accordingly a for
eign court should not be asked to do what could 
not be done in return. 
He refused to issue letters rogatory as requested 
because he was not satisfied on the conflicting 
evidence of the law in four of those jurisdictions 
that the Courts thereof would act on those letters 
(there was no evidence as to the law in the fifth 
jurisdiction) and further he was not satisfied that 
the defendant would be prejudiced by the refusal 
of the orders sought because the defendant still 
had available to it the normal party examination 
procedures under Rule 465. 
These same normal party examination proce
dures were available to the defendant in this action 
but the defendant has been adamant in its insist
ence upon examining the initial assignor and 
inventor for discovery. 
Mr. Justice Kerr in the Textron case (supra) 
clearly indicated that, in his opinion, an order for 
the discovery of an assignor resident out of the 
jurisdiction could be devised and granted. He said 
this at page 668: 
However I think that, in the absence of specific provisions 
governing the manner of the examination for discovery of 
patent assignors out of Canada, Rule 465(12) permits the 
Court to make orders for discovery analogous to the kind of 
order provided for in Rule 477(1), or even, but less preferably, 
to issue commissions for the examination with appropriate 
modifications. I need not at this stage decide what use may be 
made of the examination if it takes place, conceivably it may be 
useful, even if only informative to the plaintiff. Nor need I 
speculate as to whether the assignors will attend for examina
tion, or what recourse the plaintiff may have if they do not 
attend. 
He added at page 669: 
I would be willing to make an appropriate order for the 
requested examination for discovery of the assignors in Japan 
and Germany or as the case may be, but before making an 
order I would want to be satisfied that there would be a 
reasonable probability that it would be effective under the laws 
of those countries. 
Kerr J. based his willingness to grant such an 
order on Rule 465(12) which reads: 
Rule 465... . 
(12) Where an individual to be questioned on an examination 
for discovery is temporarily or permanently out of the jurisdic
tion, it may be ordered by the Court, or the parties may agree, 
that the examination for discovery be at such place, and take 
place in such manner, as may be deemed just and convenient. 
Under Rule 465(5) the assignor of a patent may 
be examined for discovery by any party who is 
adverse to the assignee thereof. 
The defendant meets that qualification. 
Solomon J. Rehmar meets the qualification of 
an assignor who may be examined by the defend
ant. He also meets the qualification of being "an 
individual to be questioned on an examination for 
discovery ... permanently out of the jurisdiction". 
By virtue of Rule 465(16) he: 
... shall answer any question as to any fact within his knowl
edge that may prove or tend to prove or disprove or tend to 
disprove any unadmitted allegation of fact in any pleading filed 
by the assignee... . 
The use to which an examination for discovery 
may be put at the trial of the action is outlined in 
Rule 494(9) which provides in part: 
Rule 494... . 
(9) Any party may, at the trial of an action, use in evidence 
against another party any of his examination for discovery of 
that other party, but..... 
In view of the express provision of Rule 494(9) 
the question immediately arises whether, despite 
the provision in Rule 465(5) that the assignor of a 
patent who is not a party may be examined for 
discovery by a party adverse to the assignee and 
who, under Rule 465(16), is obliged to answer 
questions with respect to any unadmitted allega
tion in the pleadings, the information so elicited 
can be used in evidence. My brother Mahoney has 
decided the question posed. I shall refer to his 
decision later. 
Mr. Justice Kerr did not decide what use could 
be made of the examination for discovery should 
he order it, other than to remark: 
... conceivably it may be useful, even if only informative to the 
plaintiff. 
Jackett C.J. in the Lido case (supra) has said 
that what is described in Rule 465(5) as the 
examination for discovery of a non-party is not 
within the normal concept of an examination for 
discovery. He describes it as the "pre-trial ques
tioning of a potential witness", the assignor of the 
industrial property right. 
With respect to Rule 465(12) upon which Kerr 
J. was prepared to place reliance to order examina
tion for discovery in the Textron case predicated 
upon the assumption that the order would be 
effective under the laws of the foreign country 
Jackett C.J., in considering Rule 465(12) in the 
Lido case said: 
Presumably, Rule 465(12) contemplates the Court authorizing 
such an examination taking place outside Canada but one does 
not find anything in the Rules authorizing the Court to order 
such a person to appear for examination inside or outside 
Canada; and any such authority would not be expected having 
regard to the provision for a subpoena in Canada-and the 
Court's inability to issue orders or other process having effect 
outside its geographical jurisdiction. 
It is this, and like considerations, which led 
Jackett C.J. to say that Rule 465(5) "cannot 
operate where the person to be examined is outside 
Canada and cannot be made the subject of a 
subpoena issued out of a Canadian court". 
As I appreciate his conclusion it is because the 
Court by its own process cannot enforce its order 
that order will not be made. The Rules of Court do 
not contemplate such an order being given. 
But Jackett C.J. did not discard the possibility 
that other methods might be available to accom
plish that same end. 
Resort may not be had to the issuance of a 
commission to examine for discovery the assignor 
of a patent to be conducted outside Canada: see 
Cameron J. in Lovell Manufacturing Co. v. Beatty 
Bros. Ltd. (supra) and Kerr J. in the Textron case. 
Neither may letters rogatory nor letters of 
request be utilized to achieve that end. See Brooke 
J.A. in Re Raychem Corp. (supra), Radio Corp. 
of America v. Rauland Corp. [1956] 1 All E.R. 
549 and Re Radio Corp. of America v. The Rau-
land Corp. [1956] O.R. 630. The reason for this is 
that letters rogatory and letters of request are for 
the purpose of taking evidence out of the jurisdic
tion for use as testimony in the action within the 
jurisdiction. They are not for the principal purpose 
to search out evidence and information in the same 
way as an examination for discovery. 
It was the view of Jackett C.J. that such would 
be possible by a duly implemented international 
convention. 
Mr. Justice Kerr in the Textron case, was not 
oblivious that there might be implemented interna
tional conventions or treaties which would permit 
an examination for discovery being held in foreign 
contracting countries but he was not referred to 
any such existing treaties. In the absence of such 
conventions or treaties he would nevertheless by 
reason of Rule 465(12) make an order analogous 
to taking evidence on commission to enable the 
conduct of an examination for discovery of the 
assignor of a patent resident out of Canada. Before 
doing so he required to be satisfied that the laws of 
the foreign jurisdiction would permit of this being 
done. 
Counsel for the defendant was undoubtedly 
aware that the United States District Court for the 
Northern District of Ohio might accede to such a 
request in view of his statement that it was done on 
three previous occasions of which he was aware 
although where these occasions occurred he did 
not say. 
In any event, when requested on an ex parte 
application, without letters rogatory or letters of 
request, to require Solomon J. Rehmar to submit 
to a "discovery deposition" to be taken on oral 
examination "for use in a proceeding now pending 
before the Federal Court of Canada, Trial Divi
sion", the United States District Court for the 
Northern District of Ohio did so and in so doing it 
acted under paragraph 1782 of the United States 
Code. 
Therefore the defendant knew that the condition 
precedent to the order that Kerr J. contemplated 
giving in the Textron case could be met, not only 
on an order emanating from this Court but with
out any such order. 
It is axiomatic that a particular court is the 
master of its own procedure and the conduct of 
proceedings before it in conformity with the gener
al law applicable and its Rules. It was for this 
reason I considered it inappropriate for the defend
ant to obtain an order from a foreign court to 
compel the attendance of an assignor of an inven
tion resident within that jurisdiction for examina
tion in relation to an action in this Court without 
first seeking such process as is available to it. 
This the defendant did not do. 
Rather this Court and its processes were 
ignored. 
It may be that a motion for directions was 
considered by the defendant as being abortive and 
contrary to its concept of what the law should be 
but that is no reason for not first determining what 
the law is by that means if any doubt existed. 
There can be no doubt that what the defendant 
sought and obtained was not the testimony of 
Solomon J. Rehmar as a witness for use in the trial 
of this action in which event there would have been 
no perceptible impediment to the order for the 
issuance of letters rogatory or letters of request. 
What was sought and what was obtained without 
letters rogatory or letters of request but on a 
unilateral application to a foreign jurisdiction is 
described as a "discovery deposition" for use in 
this proceeding before this Court. 
As I understand it an oral deposition in the 
United States is a tool for discovery and serves the 
same purpose as an examination for discovery does 
in this jurisdiction. 
Furthermore counsel for the defendant was 
candid in his admission that he did not wish to go 
to trial without first having subjected the assignor 
of the patent to an examination for discovery. He 
was not seeking the assignor's "testimony". He 
was therefore seeking information and a train of 
inquiry. 
In the application to the United States District 
Court it was alleged that the purpose of the "dis-
covery deposition" upon oral examination was "for 
use in a proceeding now pending before the Feder
al Court of Canada". 
That representation may have been misleading 
and inaccurate. At least it is ambiguous. 
Kerr J. in the Textron case did not decide what 
use could be made of the examination for discov
ery he contemplated giving other than conjecturing 
that it may be useful. 
That question arose casually during the course 
of representations by counsel for the defendant. I 
suggested that at the most it could only be used as 
a basis for cross-examination of Mr. Rehmar 
should he be called as a witness by the plaintiff at 
the trial, and I expressed reservations that any part 
of the "discovery deposition" reduced to writing 
could be used in evidence at trial under Rule 
494(9). 
By his decision in Dennison Manufacturing Co. 
of Canada Ltd. v. Dymo of Canada Ltd. (1976) 23 
C.P.R. (2d) 155 Mahoney J. resolved any such 
reservations. 
After first quoting Rule 494(9) with appropriate 
emphasis he said at page 162: 
Admissions obtained on examination for discovery are not 
voluntary; they are obtained by lawful coercion. At common 
law, they were not admissible as evidence but could be used 
only to contradict the party examined during his testimony at 
the trial. The admissibility of such admissions as evidence 
depends entirely on statute. The only statutory authority in this 
instance is Rule 494 (9). That rule is authority only for the use 
in evidence, by an adverse party, of admissions obtained from a 
party and that is limited to its use against the party who made 
the admissions and no other. The assignor is not a party and, 
even if he were, his admissions could not, under Rule 494 (9), 
be used in evidence against another party. 
The reservations I may have entertained conse
quent upon Rules 465(5) and (16) were dispelled 
by his answer to a like question posed by counsel 
for the defendant before him in these terms: 
The question posed by the defendant was: what useful pur
pose is served by permitting, under Rule 464 (5), an examina
tion for discovery of the scope defined by Rule 465 (16), unless 
the results may be used as evidence? The purposes of examina
tion for discovery were succinctly stated by Middleton, J., in 
Graydon v. Graydon (1921), 67 D.L.R. 116 at pp. 117-18: 
It is primarily for the purpose of enabling the opposite party 
to know what is the case he is to be called upon to meet, and 
its secondary and subsidiary purpose is to enable the party 
examining to extract from his opponent admissions which 
may dispense with more formal proof at the hearing. 
The primary purpose is usefully served by an examination such 
as that in question; the secondary purpose is not served and, 
indeed, ought not be served since the person being examined is 
not the defendant's "opponent" in the context of the action 
whatever his stance may be in fact. 
These considerations prompted my initial reac
tion that the matter be left to the Trial Judge in 
the event that the "oral deposition" or part thereof 
might be tendered in evidence at trial. 
But as stated the order sought by the plaintiff in 
its motion goes far beyond that and, in my view, 
there is sound reason for so seeking and ample 
jurisprudence justifying the relief sought. 
The application to the United States District 
Court was supported by an affidavit sworn by the 
solicitor for the defendant. 
In paragraph 6 thereof the affiant swears that 
central issues in the patent infringement action are 
(1) the date of the invention by the assignor and 
the nature of the invention made and (2) the steps 
from its conception to culmination which require 
explanation by the defendant. It is also sworn that 
the inventor's "testimony" is of great importance. 
Testimony is loosely used. The inventor is not 
sought as a witness. He is sought to be examined 
for discovery. That is what the paragraph of the 
affidavit establishes. 
After reciting that Mr. Rehmar is not a party to 
the action and is not resident in Canada paragraph 
9 recites that: 
There is therefore no jurisdictional basis by way of subpoena or 
otherwise upon which the Federal Court of Canada can compel 
Mr. Rehmar to submit to an examination for discovery.... 
That is accurate and I agree with that statement 
but I would put it otherwise in the light of the 
decision of Jackett C.J. in the Lido case, Brooke 
J.A. in Re Raychem Corp. v. Canusa Coating 
Systems, Inc. and in the two decisions sub nom 
Radio Corp. of America v. Rauland Corp. which 
have been quoted extensively. It is contrary to law 
for the Federal Court of Canada to so order. 
The Court will restrain a litigant before it from 
prosecuting proceedings in a foreign court for the 
purpose of searching out evidence or information 
respecting an action in the Court which proceed
ings in the foreign court are not permissible under 
its Rules. 
In The Carron Iron Co. Proprietors v. Maclaren 
(1854-56) 5 H.L. Cas. 416 the House of Lords 
held that if the circumstances were such as would 
make it the duty of one court in this country to 
restrain a party from instituting proceedings in 
another court here these circumstances will also 
warrant that court from imposing on the party a 
similar restraint with regard to proceedings in a 
foreign court. 
Lord Cranworth said at pages 436-437: 
There is no doubt as to the power of the Court of Chancery to 
restrain persons within its jurisdiction from instituting or prose
cuting suits in foreign courts, wherever the circumstances of the 
case make such an interposition necessary or expedient. The 
Court acts in personam, and will not suffer any one within its 
reach to do what is contrary to its notions of equity, merely 
because the act to be done may be, in point of locality, beyond 
its jurisdiction. 
I appreciate that the Carron case was decided in 
1855 but it has been followed and applied as late 
as 1928 by Scrutton L.J. in Ellerman Lines, Lim
ited v. Read [1928] 2 K.B. 144 (C.A.). 
In The Christiansborg (1885) 10 P.D. 141 the 
ship had been arrested and suit commenced 
against it in Holland. The ship was released from 
arrest on bail being furnished. The ship came to 
England and was there arrested by the same party 
suing in Holland. 
It was moved before Sir James Hannen for the 
release of the ship from its arrest under the second 
action in England. 
Sir James Hannen said at page 143: 
The principle on which I think that this question should be 
determined is, that where an action has been brought in one 
court, and it is not shewn that such court would not do justice, 
it is primâ facie oppressive to institute an action in any other 
court. 
On appeal Baggallay L.J. said at pages 152-153: 
I take it to be established by a series of authorities that 
where a plaintiff sues the same defendant in respect of the same 
cause of action in two courts, one in this country and another 
abroad, there is a jurisdiction in the Courts of this country to 
act in one of three ways,—to put the party so suing to his 
election, or, without allowing him to elect, to stay all proceed
ings in this country, or to stay all proceedings in the foreign 
country—it is not in form a stay of proceedings in the foreign 
court, but an injunction, restraining the plaintiff from prosecut
ing the proceedings in the foreign country, which of course 
cannot be enforced against him if he is a foreigner, and is 
neither present in this country nor has property here. It is an 
injunction which may become inoperative, but that is how the 
proceedings in the foreign Court may in effect be stayed. 
The order I granted in this matter restrains the 
defendant from prosecuting an examination for 
discovery, the order for which is not permissible 
under the law in this jurisdiction, but which was 
ordered by a foreign court with respect to a pro
ceeding completely within this jurisdiction. 
Fry L.J. said at page 155 in The Christiansborg 
(supra): 
... the institution of the action in the Admiralty Court in this 
country was against good faith. 
In Ellerman Lines, Limited v. Read (supra) it 
was held that the fact that a British subject had 
actually obtained judgment in a foreign court did 
not prevent an English court from granting an 
injunction restraining its enforcement where it was 
shown to have been obtained by breach of contract 
or by fraud. In granting an injunction the English 
court did not seek to assert jurisdiction over the 
foreign court. It restrained the person seeking to 
enforce the judgment from doing so either in 
England or elsewhere. It was an injunction in 
personam. 
The Judge of first instance had granted the 
injunction restraining the enforcement of the for
eign judgment in England but considered he had 
no authority to restrain its enforcement outside the 
jurisdiction of the English court. 
Scrutton L.J. disagreed. He said at page 151: 
They [the English Courts] do not, of course, grant an injunc
tion restraining the foreign Court from acting; they have no 
power to do that; but they can grant an injunction restraining a 
British subject who is fraudulently breaking his contract, and 
who is a party to proceedings before them, from making an 
application to a foreign Court for the purpose of reaping the 
fruits of his fraudulent breach of contract. This appears from a 
series of authorities. 
Here the injunction is not directed to the foreign 
court but to a party in an action before this Court. 
The matter was put this way by Atkin L.J. at 
page 155: 
The principle upon which an English Court acts in granting 
injunctions is not that it seeks to assume jurisdiction over the 
foreign Court, or that it arrogates to itself some superiority 
which entitles it to dictate to the foreign Court, or that it seeks 
to criticize the foreign Court or its procedure; the English 
Court has regard to the personal attitude of the person who has 
obtained the foreign judgment. If the English Court finds that 
a person subject to its jurisdiction has committed a breach of 
covenant, or has acted in breach of some fiduciary duty or has 
in any way violated the principles of equity and conscience, and 
that it would be inequitable on his part to seek to enforce a 
judgment obtained in breach of such obligations, it will restrain 
him, not by issuing an edict to the foreign Court, but by saying 
that he is in conscience bound not to enforce that judgment. 
The decision which is analogous to the facts in 
the present matter is Armstrong v. Armstrong 
[1892] P. 98. 
This was a petition for divorce by the husband 
on the ground of his wife's adultery with the 
co-respondent. The petitioner had obtained an 
order on commission to examine witnesses in 
Vienna. The co-respondent disputed the jurisdic
tion of the Court. Pending the disposition of peti
tion against the jurisdiction of the Court the com
mission to the petitioner to take evidence of the 
witnesses in Vienna was suspended. In the mean
time agents of the petitioner in Vienna summoned 
witnesses before a tribunal in Vienna appointed to 
take evidence for the perpetuation of testimony. 
This was done under an order requested of the 
Viennese Courts under Article 179 of the Austrian 
Code appointing the tribunal for that purpose. 
The proceedings in Vienna were more than the 
mere taking of proofs because the witnesses were 
examined on oath subject to the pressure of foreign 
procedure. The proceedings were not auxiliary to 
the progress of the action for this evidence when 
taken could not be used in the trial of the action 
and as such must be considered as separate and 
independent action by the petitioner and as useless 
and vexatious. 
What was sought was an injunction restraining 
the petitioner from proceeding under the order of 
the Viennese Court in relation to matters in ques
tion in the cause or alternatively that the petitioner 
elect to proceed with his suit in England or with 
the proceedings commenced by him in Vienna. 
The Court made the order restraining the peti
tioner from further prosecuting the proceedings 
before the Court at Vienna. 
In so doing Jeune J. said [at pages 100-102]: 
Is that a proceeding which this tribunal ought to permit the 
petitioner to take? I think it is not, and on two main grounds. 
First, I think it is useless, in the sense that the petitioner can 
obtain no legitimate advantage from it; secondly, I think it is or 
may be injurious to the proper course of proceeding in this 
Court. It is admitted that the evidence thus taken could not be 
used before this tribunal. Apart from other considerations, the 
Act of 1857 expressly and exhaustively provides how evidence 
may be taken, and by s. 47 it provides that in certain cases a 
commission may be issued for the examination of witnesses 
abroad in the manner therein specified. But the Court has held 
that it is not entitled to order the issue of such a commission in 
this case in the position in which it stands at the present 
moment. What has been done at Vienna has been represented 
as auxiliary to this suit; but it clearly is not auxiliary in the 
sense that the evidence taken before the Court in Vienna can in 
any way be made available before the Court here. The case of 
the Peruvian Guano Co. v. Bockwoldt (23 Ch. D. 225) appears 
to me to shew that, whether the second proceeding be before a 
foreign tribunal or a tribunal in this country, in either case the 
rule is this: that such a proceeding ought not to be allowed if a 
person can only obtain an illusory advantage from it. In this 
case I think that no legitimate advantage of any kind can be 
obtained. This brings me to the second ground to which I have 
referred. The only advantage suggested here is that the peti
tioner may be able to bring before the Vienna tribunal wit
nesses whose evidence he does not know, and to take their 
proofs under the pressure of an oath. He thus will get to know 
all that the witnesses may prove, and he will be under no 
obligation to produce that evidence before this Court, as he 
would be if the evidence were taken on commission. That 
appears to me to be an interference with the proper course of 
the administration of justice in this Court. Moreover, we do not 
know under what rule of law these witnesses may be examined. 
They may, and from what was said by Mr. Ram I gather will, 
be unwilling witnesses; and they may be subjected to questions 
in the nature of cross-examination by the petitioner's counsel, 
and, it appears also, by the Court, and, further, information 
beyond their proper evidence may be extracted from them. This 
appears to be a mode of dealing with testimony which we 
should not allow, and to go far beyond any process of discovery 
recognised in the procedure of this country. It amounts to 
interrogating your opponent's witnesses before trial. The matter 
is not made any better by the argument that the respondent 
may have the right of appearing before this tribunal; for though 
she may have a right to go, she has also a right to say that she 
will not go. It is clear to me, therefore, that the petitioner is not 
entitled to do what he has done. He can gain no legitimate 
advantage from it; on the contrary, a serious disadvantage may 
accrue to the administration of justice. I think he ought to be 
restrained from further action of this kind, and there will be a 
personal injunction on him restraining him from prosecuting 
the proceedings which he has begun before the Vienna tribunal. 
Many of the comments on the facts and the law 
made by Jeune J. may be extracted and applied to 
the facts and law in the present matter. 
Here the defendant, like the petitioner before 
Jeune J., can obtain "no legitimate advantage". 
The evidence obtained in the respective proceed
ings could not be used in the courts seized of the 
actions and neither court could nor would grant an 
order such as was granted by the foreign court. 
The advantage accruing to the defendant is an 
advantage to which, in the applicable circum
stances under the law of this jurisdiction, it is not 
entitled. That is not a legitimate advantage. The 
defendant by invoking the process of a foreign 
jurisdiction in a proceeding which is not truly 
auxiliary (and could not be without the order of 
this Court) to the action properly before this 
Court, but separate and distinct therefrom, has 
circumvented the law of this jurisdiction by which 
law this action must be governed. 
This, in my view, is a proceeding which this 
Court ought not permit the defendant to take. 
It was for those reasons that I gave the order 
that I did at the conclusion of the hearing. 
The plaintiff shall be entitled to its costs in any 
event in the cause. 
I cannot leave this matter without saying that 
my conclusion has been reached without disrespect 
to the United States District Court for the North
ern District of Ohio which these reasons should 
clearly indicate. This is what prompted me to say 
that the learned Judge of that Court had been 
placed at a disadvantage in that representations 
contrary to those of the applicant were not avail
able to him. 
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.