Alberta, Canada
The following excerpt is from Sheckter v. Western Motor Hotels (Edmonton) Ltd., 1985 CanLII 1500 (AB QB):
The effect of Ash v. Cutler (supra) appears to be that in Manitoba an application for leave to amend pleadings must be supported by an affidavit showing that there is merit in the matter sought to be introduced by a proposed amendment. Although there were some rather peculiar aspects to the factual situation in Ash, the court appears to have intended the decision to have wider reach than just the particular situation there existing.
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