It should be borne in mind however, that even a vexatious litigant can
have a legitimate complaint. It is not uncommon for there to be a real issue
at the heart of a vexatious litigant’s case . . . Care should be taken to allow
generously for drafting deficiencies and recognizing that there may be a core
complaint which is quite properly recognized as legitimate even if the proceeding itself is frivolously brought or carried out and ought to be dismissed.
C. The Principles Applied
 The basis of the motion judge’s ruling was that the statement of claim provided “no particulars whatsoever” of alleged
breaches of fiduciary duty and negligence (at para. 20), and “no
particulars whatsoever” of “fraud, misappropriation and dishonesty on the part of the defendant law firms” (at para. 21). This
criticism was repeated at para. 25.
 The motion judge also referred to “internal contradictions
in that having acknowledged in the pleading that he [the appel-lant] was told his tort action had settled for the sum of $82,500,
at paragraph 13 of the statement of claim he states that he was
told by a representative of Krylov that in fact the settlement
amount would be higher” (at para. 22).
 However, in effect and read generously, the pleading
alleges that the respondent law firms settled the motor vehicle
action for much more than they told the appellant, and pocketed
the difference between the higher amount of the settlement and
the $82,500 stated in the release. In other words, the pleading
alleges that the law firms conspired to defraud the appellant.
 As distasteful as this allegation might be, it is not entirely
implausible. A cautious approach must be taken, as Myers J.
noted in Husain v. Craig,  O.J. No. 1300, 2015 ONSC 1754
(S.C.J.), at para. 10, when he asked: “what if the plaintiff’s allegations are true”?
 Rule 2.1 is an extremely blunt instrument. It is reserved
for the clearest of cases, where the hallmarks of frivolous, vexatious or abusive litigation are plainly evident on the face of the
pleading. Rule 2.1 is not meant to be an easily accessible alternative to a pleadings motion, a motion for summary judgment
or a trial.
 The hallmarks of a vexatious pleading amenable to being
struck under rule 2.1 are well known to judges and helpfully
listed in paras. 14-15 of Gao (No. 2). However, the statement of
claim in this case bears none of them. It is short and to the
point. There is nothing on the face of the statement of claim that
shows the appellant to be a vexatious litigant or that he is
engaged in what Myers J. described in Husain as “querulous litigant behavior” (at para. 15). Nor is there any suggestion in the
material that the appellant will abuse the process of the court