An application for witness summonses on a criminal appeal will be dismissed as speculative where the applicant cannot demonstrate that the proposed witnesses are able to give relevant and admissible evidence in relation to the grounds of appeal, and instead seeks to discover whether such evidence might exist. The breadth of document production summonses must not be oppressive and unreasonable. Failure to comply with prior court orders regarding additional evidence, without adequate explanation, weighs against the application.
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