The following excerpt is from Greater Niagara Transit Commission v. A.T.U., Local 1582, 1987 CanLII 5384 (ON SCDC):
In the first place, as a general rule, interlocutory findings of fact, including rulings made upon issues involving the admissibility of evidence, in one judicial proceeding do not engage the doctrine of issue estoppel in a subsequent proceeding on account of the absence of the critical elements of finality and identity of issues: see Duhamel v. The Queen, supra.
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