Habeas petitions do not count towards vexatious litigant determination. The plaintiff was effectively declared a vexatious litigant. The doctrine of standing prevents applicants from burdening the court with frivolous or vexatious claims. Administrative tribunals in Quebec cannot declare a person a vexatious litigant. Rulings such as this have classified the Church of Scientology as a chronically vexatious litigant. Unmeritorious and vexatious claims against barristers are simply struck out. Bittaker was declared a vexatious litigant in 1993. Subsequently, at least two other South Australians have been found to be vexatious litigants. Security can also be ordered where a plaintiff is insolvent, or prone to vexatious litigation. Security can also be ordered where a claimant is insolvent, or prone to vexatious litigation. The court even dubbed it "vexatious litigation". The court also found that the original private prosecution application vexatious in nature. Examples include harming the competitive structure of the market, vexatious litigation and preferential treatment. Any gender-related description should be allowable, through the Registrar may refuse vexatious or obscene applications. Red finds his neighbors, Bob and Midge Pinciotti, perplexing and vexatious.