What is the current state of the law in relation to the production of relevant documents?

A careful reading of Geffen v. Goodman has led me to the conclusion that the liberal approach to the production of relevant documents as contemplated by Wilson J. should not be extended to the particular facts of this case. Geffen v. Goodman itself was merely an extension to the wills cases exception to the extent that discovery and production of the solicitor's client may assist the court in determining whether or not the true intention of the testator was disclosed in his or her will.

The exception in the wills cases and by extension the inter vivos trust situation as seen in Geffen v. Goodman appears to deal with the scenario where the validity of a will or the settling of an inter vivos trust is being challenged and where such challenge goes directly to the creation of the will or trust then it is in the best interests of justice to admit such evidence.

The statement of Wilson J. in Geffen v. Goodman, which I have set out supra, succinctly states that the reason why there is the exception (and which exception will not violate privilege generally) is that the interests of the now deceased client for whom the solicitor/client privilege exists are furthered in the sense that the purpose for allowing the evidence to be admitted is precisely to ascertain what his or her true intentions were when those true intentions are questioned in litigation.