Expert Witness

Richard v. 2464597 Ontario Inc., 2019 ONSC 2104 (CanLII)

[50] The formal requirements for the introduction of expert witnesses are not necessarily required in Small Claims Court. For example, there is no requirement that a voir dire take place prior to hearing expert evidence: see Sutherland Estate v. MacDonald, [1999] O.J. No. 785 (Small Claims Ct.). An expert report is not required to be filed in order for an expert to give evidence at a Small Claims Court trial: see Steckley v. Haid, [2009] O.J. No. 2014 (Small Claims Crt.); Prohaska v. Howe, supra. Nor does a witness have to be explicitly tendered as an expert witness to give an expert opinion: see Untinen v. Dykstra (2016) ONSC 4721 (Div. Ct.) at paras. 9, 29-31.