Can a statement of claim be struck where there is no reasonable cause of action?

The motion judge then noted that, on a motion under r. 21.01(1)(b), a statement of claim may be struck where, assuming the facts pleaded are true, it is plain and obvious that the pleading discloses no reasonable cause of action. He acknowledged that the standard is very low for the demonstration of a reasonable cause of action on a r. 21 motion. However, he also cited Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99, at para. 36, for the proposition that in litigation involving children a “more stringent standard” may be imposed in order to ensure the children’s best interests are protected. The motion judge stated that he would apply that “more stringent standard” to the present case.