How have courts dealt with the issue of delay in an action for delay?

In Voulgaris v. ScotiaMcleod Inc., 2006 MBQB 162, [2006] M.J. No 278 (affirmed 2007 MBCA 37, [2007] M.J. No. 88) the court dismissed an action for delay on the basis of inherent and actual prejudice. The action involved two claims which had been consolidated. The plaintiff had sued her stockbrokers for mishandling her account. The plaintiff took no active steps in the litigation for a period of six years, and the claims involved events which occurred twelve years before the hearing. The actual prejudice was serious as one of the defendants in one claim who was also a witness in the other, and whose evidence was crucial, had died. Jewers J. noted that the defendants would be at a serious disadvantage without his viva voce evidence at trial.