What is the legal test for referring to the registrar as a reference to judgment?

British Columbia, Canada


The following excerpt is from Boutsakis v. Alexis House Café Limited, 2014 BCSC 221 (CanLII):

Before I turn to further British Columbia authorities, I note that the facts in Engel v. Lautner, [1954] S.J. No. 34 (C.A.) are more relevant here in relation to references to the registrar. In that case, judgment on liability had been pronounced and a reference was made to the master to ascertain the amount. On a later application, the amount determined by the master was confirmed by the trial judge. This of course would be similar to our “report and recommendation” procedure under Rule 18-1 outlined above. The court stated that “judgment” arose only after the later application of the court to confirm the master’s determination of the amount:

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