What is the test for using improper affidavits in a civil case?

The same approach was taken by Vertes J. in Métis Nation, and Schuler J. in Woodley v. Yellowknife Education District No. 1, 2000 NWTSC 7, [2000] N.W.T.J. No.8. In the former, the conduct consisted of the use of improper and scandalous affidavits. In the latter, the blameworthy conduct consisted of the unnecessary publication, in a newspaper, of the suspension of the plaintiff employed by the District.