A student applied to compel Providence University College to disclose every record about her. There was no action between the student and the college. Justice Toews dismissed the application because Manitoba's civil discovery rules require an action and material relevant to the pleaded issues. The institution had already supplied some records voluntarily.
Why it matters. A litigant can't use the ordinary discovery rules to obtain an institution's entire file without a proper proceeding. Separate statutory access rights were not decided.