What is the basis for a motion to convert a petition into an action?

The parties join in asking that, despite the numerous and pervasive factual disputes, the petition not be converted to an action. They refer to Hryniak v. Mauldin, 2014 SCC 7, in their submissions that a fair and just adjudication can be based on the affidavit evidence filed and the submissions made. They submit that such an adjudication would be proportionate to the amount involved, the importance of the issues in dispute, and the complexity of the proceeding, and would be a more expeditious and less expensive means to achieve a just result than a trial.