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Maybe the strongest criticism of counsel’s failure to perform research was levelled in Gibb v. Jiwan, 1996 O.J. No. 1370 Q.L. (Ont. Gen. Div.) by Ferguson J. The case involved a dispute over precedence to claims from land registered underneath the Ontario Land Titles Act. Right after selecting the point of legislation, Mr. Justice Ferguson commented thoroughly on the failure of counsel to perform adequate study, noting the professional obligation of counsel:

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