Does the fact that litigation is a reasonable prospect after a casualty make a report privileged?

At page 259 of Hamalainen v. Sippola, his Lordship held that it is an error of law to assume that because litigation seemed likely, the reports must necessarily have been prepared for the required dominant purpose of litigation. His Lordship stated that such is clearly not the case as evident from the following passage at page 321 (B.C.L.R.) of the report in the Shaughnessy Golf Club case; The fact that litigation is a reasonable prospect after a casualty, and the fact that that prospect is one of the predominant reasons for the creation of the reports is now not enough. Unless such purpose is, in respect of the particular document, the dominant purpose for creating the document, it is not privileged.