Can a motion judge be found to have found that convicted offenders who have not served their sentences have standing to oppose the motion?

Counsel for the moving party relies on rule 62.02(4)(b) and takes the position that there is good reason to doubt the correctness of the decision of the motion judge in the following respects: (a) she failed to give sufficient reasons for her decision, as required in Hill v. Hamilton-Wentworth;[2] (b) she either failed to analyze at all the issue of standing raised by Ontario or, in the alternative, applied the wrong legal test in determining standing by failing to recognize that the applicant had not met his burden of demonstrating he has direct or public interest standing to raise the issue of convicted persons who are currently incarcerated or have exhausted their appeals; (c) she erred in holding in a bare conclusion that it was not plain and obvious that convicted offenders who have fully served their sentence do not have a s. 7 Charter right to “orders of production”; and (d) she either failed to analyze the issue of prematurity or, in the alternative, clearly applied the wrong legal test in determining prematurity.