“In Igbinosun v. Law Society of Upper Canada, 2009 ONCA 484, at para. 37, the Ontario Court of Appeal provided the following non-exhaustive list of considerations for deciding whether to grant an adjournment:
Factors which may support the denial of an adjournment may include a lack of compliance with prior court orders, previous adjournments that have been granted to the applicant, previous peremptory hearing dates, the desirability of having the matter decided and a finding that the applicant is seeking to manipulate the system by orchestrating delay. Factors which may favour the granting of an adjournment include the fact that the consequences of the hearing are serious, that the applicant would be prejudiced if the request were not granted, and a finding that the applicant was honestly seeking to exercise his right to counsel, and had been represented in the proceedings up until the time of the adjournment request. In weighing these factors, the timeliness of the request, the applicant’s reasons for being unable to proceed on the scheduled date and the length of the requested adjournment should also be considered.
To this list of considerations, I would add that, as in child protection cases, the consequence of an adjournment must also be measured from the child’s perspective and thus a court must consider the impact of delay on the best interests of the child: Children’s Aid Society of Toronto v. S.C.M.K., 2021 ONCJ 347, para. 11.”