What are the factors that a court should consider in deciding whether to grant leave to recall a witness?

In Griffi v. Lee, supra, at paras. 13-27, I listed factors that a court should consider when deciding whether to permit the recall of a witness.[1] I will summarize them here for convenience: (a) It is fundamental, under subrule 53.01(3), for the moving party to clearly explain why it is proposed that a witness be recalled. (b) In the presumably rare event that counsel for a moving party fails to explain why it is necessary to recall a witness, leave should not be granted. (c) Where counsel for a moving party has made a conscious and informed decision to conduct his or her case in a certain fashion and then, perhaps because things are going badly, wishes to take a different approach requiring additional evidence from a witness who has already testified, a court probably should not grant leave particularly where the decision is rooted in tactics. (d) When considering an explanation as to why a witness is to be recalled, the court must be mindful of maintaining the integrity of the Rules of Civil Procedure. (e) In circumstances where counsel for a moving party misapprehends the law and conducts his or her case consistent with the misapprehension, leave is likely to be granted so long as irreparable prejudice is not caused to the other side. (f) If recalling a witness is necessary to correct some other mistake, such as a misapprehension of the evidence, leave should be granted, however, again, only where there will be no irreparable prejudice to the opposite party. (g) Where counsel for a moving party, through inadvertence, omits to ask a question or questions of a witness, leave should be granted if, to do so, will not cause irreparable prejudice to the other side. (h) Has an intervening event rendered further questions of a witness necessary? (i) It is not sufficient that counsel for a moving party desires to put a few more questions to a witness. Recalling a witness is not meant to allow a litigant to polish his or her case. Instead, it is intended to cure a material omission in the evidence of a party such that, to refuse leave, will create the reasonable risk of a complete failure of justice based upon the court record as it stands at the time (in other words, a miscarriage of justice). (j) What will be the effect upon the opposing party, if leave is given to a moving party to recall a witness? Costs and an adjournment will cure most instances of prejudice to the opposing party. (k) In the end, after all factors have been considered, one should step back, look at the whole picture and ensure that a proper balance is struck between the accountability of counsel and the interests of justice. Will the decision of the court be fair overall? Vetting the questions to be asked on the recall