What is the test for an application to amend a reply and statement of defence to counterclaim?

Halagan v. Reifel bears some resemblance to the case at bar. In dismissing an application to amend a reply and statement of defence to counterclaim, the court made the following observations: • “… neither pleadings nor any other of the court processes are a game to be played according to what appears to be a strategic advantage at the time. The court expects a party to take a position which is consistent with its evidence and to maintain that position in its dealings with the court. In other words, saying something to one judge and saying the opposite to another will not be countenanced.”; and • “… a party must not in a subsequent pleading make any allegation of fact, raise any new ground, or claim inconsistent with the previous pleading of his.”