Affidavi / Guides / Hyperlinks case law

Motions dismissed for missing hyperlinks: what Ontario judges expect now

Updated 18 July 2026 · Ontario Superior Court of Justice

For a while, an unusable electronic record earned counsel a grumble from the bench. Then it started costing motions. Two Superior Court decisions — one dismissal, one detailed set of directions — mark where the baseline now sits.

Basaraba v Bridal Image Inc., 2021 ONSC 8038

Dunphy J. was asked to hear a motion on a large record uploaded without hyperlinks. He dismissed it — and was explicit that the record's unusability was, by itself, enough:

The absence of hyperlinks alone is "more than sufficient to warrant dismissal of this motion" — and, as the court observed, "properly hyper-linked motion records and facta are quite frankly the exception and not the rule these days."

The point was not pedantry. Navigating a large record with no links means the judge does the assembly work counsel didn't — for every exhibit reference, in both directions.

Parekh v Schecter, 2022 ONSC 302

Weeks later, Sharma J. granted the injunction sought but used the endorsement to spell out what counsel should have done. Judges cannot practically scroll a list of hundreds of separate documents; affidavits belong in one PDF with their exhibits, internally hyperlinked. The principle, in the court's words:

"In every case, materials must be uploaded with a view to ensuring they are usable by the Court."

Proper formatting, the court noted, would have materially reduced the time needed to dispose of the matter — time that is the scarcest resource in a motions court.

The practice direction already requires it

None of this is judicial improvisation. The Consolidated Civil Provincial Practice Direction and the court's Case Center guides set the same expectations in writing: documents under 500 pages, bookmarked PDFs uploaded with Import Bookmarks, factum authorities hyperlinked to public sources like CanLII (with a fully hyperlinked factum, no book of authorities is needed), compendiums with hyperlinked tables of contents, and affidavits combined with their exhibits as one linked document. The full checklist is here.

How to never be that motion

• One PDF per document; affidavit and exhibits together, linked both ways (how).
• An index whose tab numbers match the record, with each row hyperlinked to its tab (the full walk-through).
• Bookmarks mirroring the record's structure; text-searchable throughout.
• Factum authorities hyperlinked to CanLII.
• A final QA pass in the uploaded copy: click every link.

Sources: Basaraba v Bridal Image Inc., 2021 ONSC 8038 (CanLII) · Parekh v Schecter, 2022 ONSC 302 (CanLII) · Consolidated Civil Provincial Practice Direction · Commentary: Miller Thomson on hyperlinks in CaseLines

General information, not legal advice. Quotations paraphrase-checked against the reported decisions; read the full endorsements on CanLII.