The general rule is that the names of witnesses need not be disclosed. However that general rule is qualified by certain exceptions as described in Williamson v. Merril, (1904) 4 O.W.R. 528: The general rule against disclosure of the names of witnesses is modified by the rule that although one party cannot compel the other to disclose the names of his witnesses as such yet if the name of the person is a relevant fact in the case the right that would otherwise exist as to information will respond to that fact is not displaced by the assistant that such information involves the disclosure of the name of a witness.
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