Court Of Appeal Summaries (June 19 – 23, 2023) - Court Procedure

Good evening,

Following are this week's summaries of the Court of Appeal for Ontario for the week of June 19, 2023.

Ontario v Gore Mutual Insurance Company involved a contest between whether a private insurer or a public fund would be responsible to compensate the victims of a snowmobile accident. The victims were riding an uninsured snowmobile that hit a tree. One died, the other suffered serious injuries. A second snowmobile that was insured that had been following them hit the same tree right after them. The second snowmobile was "involved" in the accident of the first, and that was enough to make the insurer of the second snowmobile liable, even though the second snowmobile did not collide with the first or cause the collision of the first snowmobile. Causation was not part of the test to determine whether the insurer was liable.

In Beardwood v Hamilton (City), the Court allowed the appeal from the dismissal of the claim against the City. The Court held that the trial judge committed a palpable and overriding error in holding that the City did not have a duty to repair the road and that the appellant was 50% negligent.

Walma v Georgian Bluffs (Township) was a dispute regarding whether the Township of Georgian Bluffs and the Crown have a legal responsibility to maintain a road which provided access to the respondent's property. The Court allowed the Crown's appeal on procedural grounds. Neither the applicant nor the Township had sought any relief against the Crown. The application judge therefore had no basis to make an order against the Crown. The Township's appeal was dismissed.

Madi v King involved a claim by a non-titled spouse to share in the increase in value of the matrimonial home arising after the date of separation. There is no right to a share of the increase unless a claim such as constructive trust is asserted. There was no basis to award a post-separation increase in value in this case, and the appeal was allowed on that issue.

Zhao v Xiao, dealt with retroactive child support, for which there was no basis in this case.

Wishing everyone an enjoyable weekend.

John Polyzogopoulos
Blaney McMurtry LLP
416.593.2953 Email

Ines Ferreira
Blaney McMurtry LLP
416.593.2953 Email

Civil Decisions

Ontario (Government and Consumer Services) v Gore Mutual Insurance Company, 2023 ONCA 433

Keywords: Contracts, Insurance, MVA, Statutory Accident Benefits, Civil Procedure, Arbitration, Standard of Review, Error of Law, Insurance Act, R.S.O. 1990, c. I.8, s. 268(2), Fault Determination Rules, O. Reg. 668, Arbitration Act, 1991, S.O. 1991, c. 17, section 45, Canada (Director of Investigation and Research) v Southam Inc., [1997] 1 S.C.R. 748.

Beardwood v Hamilton (City), 2023 ONCA 436

Keywords: Torts, MVA, Municipal Liability, Road Repair, Municipal Act, 2001, S.O. 2001, c. 25, ss. 44(3) and (4), Minimum Maintenance Standards for Municipal Highways, O Reg. 239/02, Fordham v Hutton Dunwich (Municipality), 2014 ONCA 891.

Walma v. Georgian Bluffs (Township), 2023 ONCA 431

Keywords: Real Property, Municipal Liability, Road Repair, Expropriation, Civil Procedure, Applications, Procedural Fairness, Limitations Act, 2002, SO 2002, c. 24 Sched. B., The Highway Act, S.U.C. 1810 (50 Geo. III), c. 1, s. 12., Municipal Act, R.S.O. 1990, c. M.45., Rules of Civil Procedure, R.R.O. 1990, Reg. 194.

Madi v. King, 2023 ONCA 443

Keywords: Family Law, Property, Equalization of Net Family Property, Matrimonial Home, Unjust Enrichment, Constructive Trust, Proprietary Estoppel, Child Support, Section 7 Expenses, Family Law Act, R.S.O. 1990, c. F.3, ss. 5(6), 5(7), Federal Child Support Guidelines, SOR/97-175, s. 7, 19(1), Martin v. Sansome, 2014 ONCA 14, Bakhsh v. Merdad, 2022 ONCA 1, McNamee v. McNamee, 2011 ONCA 533, Ward v. Ward, 2012 ONCA 462, Doef's Iron Works Ltd. v. Mortgage Corp. Canada Inc., 2004 CanLII 34620 (Ont. C.A.), Garland v. Consumers' Gas Co., 2004 SCC 25, Cowper-Smith v. Morgan, 2017 SCC 61, Spadacini-Kelava v. Kelava, 2020 ONSC 7907, Scholz v. Scholz, 2013 BCCA 309, Korman v. Korman, 2015 ONCA 578.

Zhao v. Xiao, 2023 ONCA 453

Keywords: Family Law, Child Support, Section 7 Expenses, Family Law Act, R.S.O. 1990 c. F.3., s. 37(2.3), Federal Child Support Guidelines, SOR/97-175, s. 7, S.(D.B.) v. G.(S.R.) 2006, 2 S.C.R. 231, Michel v. Graydon, 2020 SCC 24, Lesko v. Lesko, 2021 ONCA 369, Hickey v. Hickey, [1999] 2 S.C.R. 518.

Short Civil Decisions

Novosel v. Campisi, 2023 ONCA 439

Keywords: Contracts, Solicitor and Client, Contingency Fee Agreements, Solicitors Act, R.S.O. 1990, c. S.15, ss. 24 and 25, Courts of Justice Act, R.S.O. 1990, c. C.43, ss. 6(2), Raphael Partners v. Lam, 61 O.R. (3d) 417 (C.A.), Newell v. Sax, 2019 ONCA 455.

Peters v. SNC-Lavalin Group Inc., 2023 ONCA 438

Keywords: Costs, Partial Indemnity, Public Interest Litigation, Markowich v. Lundin Mining Corporation, 2023 ONCA 359.

CIVIL DECISIONS

Ontario (Government and Consumer Services) v Gore Mutual Insurance Company, 2023 ONCA 433

Lauwers, Huscroft and Zarnett JJ.A

Counsel:

A. Camporese, for the appellant

J. Friendly and D. Higginbotham, for the respondent

facts:

In 2013, the driver of an uninsured snowmobile was killed, and a passenger was injured, after that vehicle, and an insured snowmobile that was accompanying it, struck a tree at almost the same time. Statutory accident benefits were payable for the injured passenger and for the death of the driver. The issue that arose was who would pay the funds: the appellant (the private insurer of the insured snowmobile) or the publicly funded respondent.

Section 268(2) of the Insurance Act sets out rules for determining liability for statutory accident benefits. Under the rules, even though the deceased driver and injured passenger were riding on an uninsured snowmobile, the liability would fall on the appellant if the snowmobile it insured was properly considered to have been "involved in the incident from which the entitlement to statutory accident benefits arose". Otherwise, the liability would fall on the respondent.

At arbitration, an arbitrator held that the respondent was liable. In his view, the injuries to the deceased driver and passenger of the uninsured snowmobile would have occurred whether or not the appellant-insured vehicle had been following it.

The respondent appealed to the Superior Court and the judge reversed the Arbitrator's decision, holding that the Arbitrator had erred in law by applying the wrong legal test to the question. In his view, the Arbitrator erroneously injected a causation requirement into the analysis.

issues:

Did the appeal judge err in his interpretation of the Arbitrator's decision in determining that a question of law was involved, and in reversing the Arbitrator's decision once he concluded that the Arbitrator erred in law?
Did the appeal judge err in concluding that, in the absence of the causation requirement imported by the Arbitrator, the other factors were sufficient to meet the requirements of s. 268(2)1(iii)?

holding:

Appeal dismissed.

reasoning:

The Court held that the appeal judge was correct to conclude that the Arbitrator made causation part of the test he was to apply, and that this legal error affected the result the Arbitrator reached.

The factors that are relevant to "involvement include: (i) whether there is contact between the vehicles; (ii) the physical proximity of the vehicles; (iii) the time interval between the relevant actions of the two vehicles; (iv) the possibility of a causal relationship between the actions of one vehicle and another; and (v) whether it is foreseeable that the actions of one vehicle might directly cause harm or injury to another vehicle and its occupants.

The Arbitrator clearly articulated and applied a test in which causation is required, both for this case and as a general matter in the application of s. 268(2)1(iii) to cases where the vehicles do not collide. He did not simply look for a possibility of causation, nor did he consider it to be one factor among many. For the Arbitrator, causation was a sine qua non to a finding of involvement. The Arbitrator held that the absence of causation in this case meant that the insured vehicle was not involved in the incident giving rise to the benefits entitlement. The articulation and application of the incorrect legal test was an error of law.

The Court held that the appeal judge did not err in concluding that, in the absence of the causation requirement imported by the Arbitrator, the other factors were sufficient to meet the requirements of s. 268(2)1(iii). The temporal, spatial, and participatory factors were sufficient to conclude that there was involvement.

Beardwood v Hamilton (City), 2023 ONCA 436

Simmons, Harvison Young, and George JJ.A.

Counsel:

Grosso and K. Jossul, for the appellant

facts:

In 2015, the appellant broke his left tibia when he fell off his motorcycle in Hamilton (the "City"). The trial judge accepted that a longitudinal discontinuity or lip in the pavement of the road the appellant was traveling on caused the appellant to lose control of his motorcycle after stopping at a stop sign and that the Fordham test had been satisfied.

Nonetheless, the trial judge dismissed the appellant's action for damages against the City, holding that the City had established a defence under s. 44(3)(c) of the Municipal Act, 2001 (the "Act"), which provides that a municipality is not liable for failing to keep a highway in a reasonable state of repair if minimum standards have been met.

The applicable Minimum Maintenance Standards ("MMS") established under s. 44(4) of the Act provided for a 5 cm height threshold necessary to trigger a repair obligation on the City. The only evidence concerning the height of the discontinuity came from an expert witness called by the appellant who concluded from an inspection of photographs that the height of the curb ranged between 3.5 and 5.5 cm.

The trial judge found that the heights were within the 5 cm threshold. He, therefore, concluded that the roadway where the accident happened was deemed to be in a state of repair and that the City was not responsible for the appellant's damages.

issues:

Did the trial judge err in holding that the evidence established that the height of the discontinuity met the MMS standard?
Did the respondent meet its onus of proving it was entitled to a statutory defence under s. 44(3) of the Act?
Did the trial judge err in holding that the appellant was 50% contributorily negligent?

holding:

Appeal allowed.

reasoning:

The trial judge committed a palpable and overriding error in holding that the evidence established that the height of the discontinuity met the MMS standard.

The trial judge approached determining the height of the road discontinuity in two ways. He began with the evidence of the appellant's expert, accepting the expert's critique of the raw numbers, and held it would not be appropriate to accept either of the extremes in the identified range. The trial judge relied on the average produced by the expert's range.

The trial judge's approach of assessing the height of the discontinuity by using the average was an error because it amounted to guesswork superimposed on the speculation of the appellant's expert. The fact that it was the appellant's expert who came up with the estimated range did not mean that it was anything more than speculation or that the trial judge could treat it as providing an accurate assessment of the range in heights of the pavement discontinuity.

The Court stated that the trial judge also erred in accepting the photographic evidence of the accident scene as depicting accurate and reliable measurements in the absence of evidence from the person who took the photographs who could testify to issues the appellant's expert had identified.

The Court explained that the fact that the appellant introduced the photographic evidence through his expert did not relieve the respondent of its obligation to prove that the height of the discontinuity was less than the 5 cm MMS standard for repair. The appellant's expert did not accept the photographic evidence as providing a precise or accurate depiction of the height of the discontinuity. It was up to the respondent to call evidence to establish the reliability and accuracy of the photographic evidence or some other accurate measure of the range in heights of the pavement discrepancy. It failed to do so, and therefore failed to meet its onus of proving it was entitled to a statutory defence under s. 44(3) of the Act.

Yes.

The Court stated that, because it was an alternative finding, the trial judge's analysis of the contributory negligence issue was brief. He made no reference in his analysis to important evidence relating to this issue. Similarly, the Court found that the trial judge made no reference to the appellant's evidence about his perceptions of the pavement in front of him while stopped at the stop sign. The trial judge's failure to advert in his analysis to this relevant and material evidence amounted to a palpable and overriding error.

The Court concluded that if any fault could be attributed to the appellant for the accident, the percentage was negligible and attributed 100% of the fault to the respondent.

Walma v. Georgian Bluffs (Township), 2023 ONCA 431

Lauwers, Huscroft and Zarnett JJ.A

Counsel:

Hill and L. Dean, for the appellant The Corporation of the Township of Georgian Bluffs

Thompson and M. Ion, for the appellant His Majesty the King in Right of Ontario

J. Damstra and M. McGuckin, for the respondent

facts:

In 1976, the respondent purchased lots 21 and 22 of Concession 3 (the "property") in Keppel Township, which has since been amalgamated into the Township of Georgian Bluffs. The property is situated in a wetland known as the Long Swamp within the Sauble River watershed. It includes a 70-acre elevated area to the south, once used as a pasture, and a 110-acre downward slope on the north end on which there is timber.

In 2016, the respondent contacted an arborist to carry out logging work on the property, but the arborist could not complete the work because the access road was submerged and rendered impassable because of flooding. The respondent sought to identify the owner of the access road, who was responsible for maintaining it, and who was responsible for the flooding. The Township advised that the access road is an "unopened road allowance" the Township was not required to repair or maintain. The Township asserted that it had never undertaken any maintenance of these road allowances and had not modified or in any way altered the original drainage of the respondent's or the adjacent properties. The Township notified the respondent that it would be prepared to enter into a Limited Services Agreement, which would permit him to make the necessary upgrades provided that he obtained approvals from the local conservation authority.

The respondent sought a declaration that the access road is a "forced road", that the Township had an obligation to maintain it, and that it had failed to do so, along with an order requiring the Township to restore the road to his property. In the alternative, he sought a declaration that the property had been constructively expropriated or suffered injurious affection by the Township's actions or omissions, entitling him to compensation. The Ministry was added as a party because its approval was required to connect the access road to Highway 6.

The application judge concluded that the access road is a public road that the Township was required to maintain. The application judge also made several findings against the Crown. He found that the Ministry caused the flood during the 2012-13 reconstruction by removing a culvert under the access road, and enlarging nearby culverts under Highway 6. The application judge also found that the Ministry's actions in altering the culverts led to flooding of the property, thereby depriving the respondent of all reasonable uses, thus constituting a de facto expropriation.

issues:

Were the orders made against the Crown done in a procedurally unfair manner?
Did the application judge err in concluding that the access road is a public road and in ordering the Township to restore it?

holding:

Crown's appeal allowed. Township's appeal dismissed.

reasoning:

The Court agreed with the Crown that the orders made against it were procedurally unfair. The Court noted that no orders were sought against the Ministry in the respondent's notice of application, which was commenced solely against the Township. The Ministry was added as a party on consent on a motion by the Township, but there was no notice of application or pleading from the Township seeking relief against the Ministry. Thus, the Ministry did not know the case it had to meet. The Court concluded that the orders made against the Ministry were outside the boundaries of the application.

2. No

The Township argued that the application judge misunderstood the common law test for dedication and acceptance of a private road as a public highway. The Court rejected this argument and indicated that it was an invitation to remake findings made by the application judge without basis to do so. The Court held that the application judge applied the correct legal test, and his decision is subject to review only for palpable and overriding error. The Township failed to establish any such error.

Madi v. King, 2023 ONCA 443

Pepall, van Rensburg and Harvison Young JJ.A.

Counsel:

E. Lepine, for the appellant

L. Sharp, for the respondent

facts:

The parties married in 2014 and bought a house that became their matrimonial home. Title of the home was taken in the name of the appellant alone. Although they separated in November 2019, the parties continued to live in the matrimonial home together until May 2020. They agree the matrimonial home had a value of $672,500 on the valuation date, which was the date of separation under s. 4(1) of the Family Law Act ("FLA"), but that it was sold for $860,000 in September of 2020. The parties disagree as to the respondent's right to share in the increase in the value of the matrimonial home after the date of separation.

The trial judge held that the $187,500 post-separation increase in the value of the matrimonial home was to be divided equally between the parties on the basis that the house had been held in trust by the appellant for both parties. The trial judge stated that the basis of the respondent's claim was her belief "that she was always promised and always told that they were buying a house together and that she would be an equal owner".

There was no dispute that the respondent wanted to be "on title" but not on the mortgage. The appellant advised their real estate lawyer of her wish. The lawyer's evidence at trial confirmed that he had advised the parties that they could not have the respondent on title if she was not also a principal debtor under the mortgage because the bank would not permit it. In the result, title was placed in the appellant's name alone. The respondent signed a spousal consent for the mortgage, which was necessary as the house was to be a matrimonial home.

The trial judge declined to find that the respondent was purposely misled and rejected the submission that the appellant would be unjustly enriched by receipt of the post-valuation date increase in the value of the matrimonial home, noting that "[he] contributed all of the funds used to purchase the property and paid the mortgage and household expenses both during the marriage and post-separation."

However, the trial judge accepted the respondent's evidence that she still thought that they owned the house "together" and was surprised to find out that she was not on title. He continued to set out his conclusion that the net proceeds of the sale of the house should be equally divided.

issues:

Did the trial judge err in his treatment of the post-valuation date increase in the value of the matrimonial home?
Did the trial judge err in determining the income of both parties for child support purposes?
Did the trial judge err with respect to his s. 7 expense order?

holding:

Appeal allowed in part.

reasoning:

The appellant argued that the trial judge erred in ordering that the home was the subject of a trust for a number of reasons. First, he argued that the trial judge conflated promissory and proprietary estoppel in his reasons, neither of which, he submitted, applied. Second, he submitted that the trial judge erred in basing his finding upon the "reasonable expectations of the Respondent". He further argued that even if the proprietary estoppel test had been met, the remedy was not appropriate as it was not proportional to the detriment suffered by the respondent.

The Court agreed, stating that the trial judge erred in conflating the legal principles and that proprietary estoppel could not be applied. The Court stated that the starting point for any consideration of property division and entitlement following separation is the applicable statutory scheme. Section 5(7) of the FLA sets out the purpose of equalization and makes clear that the Act is intended to address the financial unfairness that would otherwise routinely arise from marriage breakdown.

The Court noted that one important feature of the equalization scheme is the special status of the matrimonial home, which is included in the net family property of the titled spouse(s). However, the scheme does not give a non-titled spouse the right to share in property arising after the date of separation. A non-titled spouse may still seek to share in the post-separation increase in the value of the matrimonial home by making a claim for unequal division under s. 5(6) of the FLA, or a distinct ownership claim such as an equitable trust claim. There was no basis for such claims in this case.

2. No.

The appellant's income at trial was $160,000. The respondent asked the trial judge to impute to him an additional income of $9,600 to reflect the fact that he assists his father in running his business, work for which his father compensated the appellant before the parties separated. The trial judge agreed with the respondent that additional income should be imputed to the appellant for support purposes to reflect the compensation he could obtain from his father for his assistance with his business. By contrast, the trial judge set the respondent's income at $65,875 for child support purposes. He explained that although her current income was $79,309, "her contract only began on September 1st", she had "earned only $52,710.00" the previous year, and her "previous attempts at employment were either terminated early or were not renewed in part due to the manifestation of her anxiety disorder."

The appellant opposed these determinations made by the trial judge on two grounds:

First, the appellant argued that the trial judge erred in imputing additional income to him after having determined that none of the circumstances under s. 19(1) of the Federal Child Support Guidelines applied. Section 19(1) of the Guidelines contain a non-exhaustive list, and the Court found no basis to interfere with the trial judge's discretion.

Second, the appellant argued that the trial judge erred in averaging the respondent's income for child support purposes. The Court disagreed. The trial judge gave very clear reasons for setting the respondent's income lower.

3. No.

The trial judge ordered the respondent to pay "her proportion of s. 7 expenses which would be 28 percent of any reasonable extraordinary expenses." The appellant expressed concern that the respondent would object to contributing to certain expenses. This concern was rooted in the potentially ambiguous language in the trial judge's order which provides only for "agreed upon extracurricular activities." In oral submission, counsel for the respondent advised that this was not an issue and that she accepts that she is responsible for 28 percent of expenses such as childcare, medical, health and dental expenses. The Court indicated that if parties remained unclear about the interpretation, the issue should be returned to the trial judge for clarification.

Zhao v. Xiao, 2023 ONCA 453

Simmons, Harvison Young and George JJ.A.

Counsel:

M. J. Stangarone, for the appellant

T. Matthews, for the respondent

facts:

The appellant mother and the respondent father divorced in 2003. They have two children together. They filed a joint affidavit in the divorce proceeding setting out agreements they had reached. Their agreements included the following provisions:

a) the father would pay child support to the mother of $950 per month for each child "according to the child support guideline";

b) the amount of child support could be changed based on future changes in the husband's income, based on 17% of the husband's gross income for each child to be paid monthly until each child reached the age of 18;

c) if the wife remarried, the amount of child support would be reduced from 17% to 12.5% of the husband's taxable income; and

d) the matrimonial home would be transferred to the wife in exchange for a payment of $79,000 (later decreased to $74,600) in monthly instalments equivalent to the monthly child support commencing May 1, 2006, but to be repaid immediately upon the wife remarrying.

The matrimonial home was transferred to the appellant pursuant to the agreement. Although she remarried in 2006, the appellant mother did not advise the respondent of this, and the payment for the matrimonial home was not paid on an accelerated basis as stipulated in the agreement. Nor did the respondent provide his annual income information, as would have been necessary to calculate the monthly child support payment to be offset against the amount owing on the property.

In November 2016, the appellant, having unsuccessfully sought disclosure from the respondent as to his income, commenced an application for child support and other relief.

issues:

Did the Superior Court appeal judge err by upholding the application judge's decision to not award retroactive child support for the period of May 1, 2006, to June 2, 2013?
Did the application judge err in her approach in calculating the appellant mother's share of s. 7 expenses?
Did the application judge err in determining that child support should end when the children reach the age of 25?

holding:

Appeal dismissed.

reasoning:

The application judge found that the agreement between the parties that child support would be offset commencing May 1, 2006, by $74,600 owed by the mother to the father for the transfer to her of his share in the matrimonial home constituted special provisions that directly benefitted the children during this period. She therefore held that ordering child support for this period would be unfair and inequitable within the meaning of s. 37(2.3) of the Family Law Act. The Superior Court appeal judge found no error in this conclusion. The Court also saw no basis on which to interfere with this finding.

The Court found that as the mother had remarried in 2006, the application judge calculated the quantum of child support payable from 2006 to 2013 based on the 12.5% of the father's income per child formula set out under the parties' agreement. This amount was roughly equivalent to what would have been prescribed by the Federal Child Support Guidelines for the same period. Based on these figures, the application judge concluded that the amount owing for child support from 2006 to 2013 was essentially offset by the amount the mother owed the father with respect to his share in the matrimonial home.

The Court also found that in assessing the date for commencement of retroactive child support, the application judge was entitled to consider the parties' property agreement within the context of the special provisions set out in 37(2.3) of the Family Law Act. The parties' property agreement was intertwined with the father's child support obligations. The Court found that the application judge made no error in considering it when determining what weight to assign to the father's failure to notify the mother of changes in his income between 2006 and 2013.

The Court also rejected the appellant's submission that the Superior Court appeal judge erred in upholding the application judge's order that ongoing special and extraordinary expenses for the children be shared by the parties in proportion to their household incomes.

Under s. 7 of the Federal Child Support Guidelines, the court may make an order for payment of such expenses taking account, among other things, of the reasonableness of the expense in relation to the means of the parents or spouses and those of the child.

The Court held that while the guiding principle is that s. 7 expenses are to be shared by the parties in proportion to their own income, it was not unreasonable for the application judge to apportion the s. 7 expenses based on each party's household income given the facts of this case.

The Court also held that the Superior Court appeal judge did not err in upholding the application judge's determination that child support should end upon each child's 25th birthday.

The application judge fully considered all the circumstances of the children and their parents. The Superior Court appeal judge saw no basis on which to interfere, and the Court saw no basis on which to interfere with his conclusion.

SHORT CIVIL DECISIONS

Novosel v. Campisi, 2023 ONCA 439

Miller, Paciocco and Coroza JJ.A.

Counsel:

Ismail, for the appellants

Wynperle, for the respondent

Peters v. SNC-Lavalin Group Inc., 2023 ONCA 438

Paciocco, George and Favreau JJ.A.

Counsel:

Strosberg and S. Robinson, for the appellant/respondent by way of cross-appeal

Kay, D. Murdoch, S. Hennig and H. Wafaei, for the respondents/appellants by way of cross-appeal

Yang and M. Waddell, for the Law Foundation of Ontario, respondent by way of cross-appeal

Keywords: Costs, Partial Indemnity, Public Interest Litigation, Markowich v. Lundin Mining Corporation, 2023 ONCA 359.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be ought about your specific circumstances.

Canada: Court Of Appeal Summaries (June 19 – 23, 2023)
Blaney's Appeals

Table of Contents

Civil Decisions

Short Civil Decisions

CIVIL DECISIONS

SHORT CIVIL DECISIONS

Canada: Court Of Appeal Summaries (June 19 – 23, 2023) Blaney's Appeals

Table of Contents

Civil Decisions

Short Civil Decisions

CIVIL DECISIONS

SHORT CIVIL DECISIONS

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Canada: Court Of Appeal Summaries (June 19 – 23, 2023)
Blaney's Appeals