By Marco Falco ( March 21, 2022, 8:58 AM EDT) -- Canadian appellate courts are reluctant to have an appeal dismissed without a full hearing on the merits. That being said, where an appeal has little merit, where the appellant may not have the ability to pay an adverse costs award, or where the appeal is being brought for an improper or ulterior motive, the respondent may bring a motion for “security for costs” at the outset of the appeal under Rule 61.06 of Ontario’s Rules of Civil Procedure, R.R.O. 1990, Reg. 194 (the Rules)....