What is the test for a motion to compel a defendant to undergo a psychiatric examination?

In Valentin v. Winkler (1995), 7 E.T.R. (2d) 84 (B.C.S.C.), the court stated that Rule 30(1) requires that the applicant establish that a person's physical or mental condition is in issue "in the proceeding". Even if the condition is established, the order is then a discretionary one. The court in that case concluded that the plaintiff's mental condition was not in issue. However, the court went on at para. 16: 16. If I am wrong in my conclusion that the plaintiff's mental condition is not in issue "in the proceeding" as that phrase is to be interpreted in R. 30, then I would exercise my discretion against the granting of the order. I would do so because, in my view, in a case such as this where it is the fundamental capacity of the party which is at issue, the party putting that fundamental capacity in issue ought to be required to do far more than simply allege incapacity in the pleadings. He ought to be required to put forward cogent evidence which establishes real question as to the other party's capacity which justifies requiring that party to undergo the psychiatric examination. In my opinion, the defendant's evidence falls short of that standard.