What is the standard of pleading in a class action?

Neither the CPA nor the Rules of Civil Procedure provide rules of pleading specifically applicable to class proceedings. This is consistent with the view that, although any compensatory damages sought will invariably reflect the intention to move for certification on behalf of the class, a statement of claim need - and, perhaps, should - otherwise focus primarily on the claims of the plaintiffs and allege the facts material to them. Any questions relating to the existence, nature and extent of the claims of other class members would then fall to be dealt with on a motion to certify the proceedings in the context of the inquiry into the proposed common issues and the required rational connection between them and the class definition as defined in the notice of motion. I believe that, in principle, this is the correct approach to pleading under the CPA. In my experience it is consistent with the approach most commonly adopted by plaintiffs’ counsel in class proceedings although, at times, statements of claim have been drafted as if the putative class members were plaintiffs: see, for example, Healey v. Lakeridge Hospital et al, [2006] O.J. No. 4277 (S.C.J.), at para 26.