Bibliographic record
Abstract
The spread of the real and substantial connection test adopted in Morguard Investments Ltd. v. De Savoye has been a remarkable phenomenon. Morguard lifted the phrase from the House of Lords divorce recognition case Indyka v. Indyka and applied it to the enforcement of money judgments between Canadian provinces. Subsequent lower court judgments held that the real and substantial connection standard should be extended to the enforcement of money judgments from foreign countries, and this was eventually confirmed by the Supreme Court in Beats v. Saldanha. The same test was also applied to the adjudicatory jurisdiction of the superior courts of the Canadian provinces, where it operates to police the application of service ex juris rules.These two extensions of the real and substantial connection criterion were foreshadowed by obiter dicta in Morguard and are unsurprising. Other new uses for the test were less predictable and more controversial. In its 1993 decision in Hunt v. T&N PLC the Supreme Court of Canada constitutionalized the Morguard doctrine and held that it might be used to render provincial blocking statutes constitutionally inapplicable insofar as they might limit the reach of another province's discovery process. A decade later, in Unifund Assurance Co. of Canada v. Insurance Corp. of British Columbia, the Supreme Court found yet another use for Morguard's, real and substantial connection standard: the test could be employed to determine the territorial scope of overlapping provincial statutes
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.003 | 0.008 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.005 | 0.003 |
| Scholarly communication | 0.005 | 0.002 |
| Open science | 0.001 | 0.002 |
| Research integrity | 0.005 | 0.005 |
| Insufficient payload (model declined to judge) | 0.006 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".