The Court of Appeal confirmed that a pleading's reference to a 'resolution' does not constitute a clear and unambiguous reference to a document for the purposes of UCPR r 222, even where the relevant statute uses the term 'resolution' and it would be expected that such resolutions are recorded in writing. The mere likelihood or inference that a document must exist is insufficient to enliven r 222; a party seeking production must instead pursue disclosure through other procedural mechanisms.
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