From: Small Claims Court: Procedure and Practice (4th edn., 2017), p. 48.
'Rule' refers to the Rules of the Small Claims Court, O Reg 258/98. This post involves only liquidated claims.
[p. 198:] Unliquidated Claims (Rule 11.03)
A defendant who fails to deliver a defence to a plaintiff's or defendant's claim where all or part of the claim is for an unliquidated amount may be noted in default pursuant to Rule 11.01 However, the plaintiff may obtain a default judgment in an unliquidated claim only if all defendants have been noted in default (Rule 11.03(1)).
[p. 208 Bottom] The clerk cannot sign default judgment in an unliquidated claim.
[p. 267] If a defendant by defendant's claim fails to file a defence within the prescribed time, she may be noted in default. However, the clerk cannot sign default judgment against a defendant by defendant’s claim who has been noted in default. Judgment against a defendant by defendant’s claim who has been noted in default must be obtained at trial or on motion (Rules 10.05(2) and 11.04).