What are the rules relating to perfection of an order made in chambers but withdrawn in open court?

It is perhaps useful to begin by noting that the decision deals with an order originally pronounced in chambers but apparently withdrawn in open court. I think it is clear that the rules relating to the perfection of orders made in chambers are the same as those relating to the perfection of judgments and orders made in court. Apart from the wording of the rules themselves, the decision of Ballard v. Tomlinson (1883), 48 L.T. 515, is old authority for a long-held practice. That was also an action for contempt for noncompliance with an order of the court, in that case an order to answer certain interrogatories by a day which had passed. Pearson J. stated: . . . although it is a common thing in ordinary cases not to incur the useless trouble and expense of entering orders made by the chief clerks at chambers, at the same time . . . I am unable to hold that such orders can be enforced by attachment or committal unless they have been entered . . . [emphasis added]

Indeed, an argument has been made in cases such as Fawkes v. Swayzie (1899), 31 O.R. 256 (Div. Ct.), which might suggest that the less formality in the circumstances in which the decision was made, the more formality is useful in the perfection of the order.