Yaiguaje et al. v. Chevron Corp. et al., (2015) 474 N.R. 1 (SCC)

JudgeMcLachlin, C.J.C., Abella, Rothstein, Cromwell, Karakatsanis, Wagner and Gascon, JJ.
CourtSupreme Court (Canada)
Case DateDecember 11, 2014
JurisdictionCanada (Federal)
Citations(2015), 474 N.R. 1 (SCC);2015 SCC 42;[2015] 3 SCR 69;388 DLR (4th) 253

Yaiguaje v. Chevron Corp. (2015), 474 N.R. 1 (SCC)

MLB headnote and full text

[French language version follows English language version]

[La version française vient à la suite de la version anglaise]

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Temp. Cite: [2015] N.R. TBEd. SE.001

Chevron Corporation and Chevron Canada Limited (appellants) v. Daniel Carlos Lusitande Yaiguaje, Benancio Fredy Chimbo Grefa, Miguel Mario Payaguaje Payaguaje, Teodoro Gonzalo Piaguaje Payaguaje, Simon Lusitande Yaiguaje, Armando Wilmer Piaguaje Payaguaje, Angel Justino Piaguaje Lucitante, Javier Piaguaje Payaguaje, Fermin Piaguaje, Luis Agustin Payaguaje Piaguaje, Emilio Martin Lusitande Yaiguaje, Reinaldo Lusitande Yaiguaje, Maria Victoria Aguinda Salazar, Carlos Grefa Huatatoca, Catalina Antonia Aguinda Salazar, Lidia Alexandria Aguinda Aguinda, Clide Ramiro Aguinda Aguinda, Luis Armando Chimbo Yumbo, Beatriz Mercedes Grefa Tanguila, Lucio Enrique Grefa Tanguila, Patricio Wilson Aguinda Aguinda, Patricio Alberto Chimbo Yumbo, Segundo Angel Amanta Milan, Francisco Matias Alvarado Yumbo, Olga Gloria Grefa Cerda, Narcisa Aida Tanguila Narvaez, Bertha Antonia Yumbo Tanguila, Gloria Lucrecia Tanguila Grefa, Francisco Victor Tanguila Grefa, Rosa Teresa Chimbo Tanguila, Maria Clelia Reascos Revelo, Heleodoro Pataron Guaraca, Celia Irene Viveros Cusangua, Lorenzo Jose Alvarado Yumbo, Francisco Alvarado Yumbo, Jose Gabriel Revelo Llore, Luisa Delia Tanguila Narvaez, Jose Miguel Ipiales Chicaiza, Hugo Gerardo Camacho Naranjo, Maria Magdalena Rodriguez Barcenes, Elias Roberto Piyahuaje Payahuaje, Lourdes Beatriz Chimbo Tanguila, Octavio Ismael Cordova Huanca, Maria Hortencia Viveros Cusangua, Guillermo Vincente Payaguaje Lusitante, Alfredo Donaldo Payaguaje Payaguaje and Delfin Leonidas Payaguaje Payaguaje (respondents) and International Human Rights Program at the University of Toronto Faculty of Law, MiningWatch Canada, Canadian Centre for International Justice and Justice and Corporate Accountability Project (interveners)

(35682; 2015 SCC 42; 2015 CSC 42)

Indexed As: Yaiguaje et al. v. Chevron Corp. et al.

Supreme Court of Canada

McLachlin, C.J.C., Abella, Rothstein, Cromwell, Karakatsanis, Wagner and Gascon, JJ.

September 4, 2015.

Summary:

The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador. The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages. They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants). Without attorning to the court's jurisdiction, the defendants moved for an order setting aside the service ex juris of the claim against them, a declaration that the Ontario court had no jurisdiction to hear the action and an order dismissing or permanently staying the action.

The Ontario Superior Court, in a decision reported at [2013] O.T.C. Uned. 2527, held that the Ontario courts had jurisdiction to hear the action, but stayed the action on its own initiative under s. 106 of the Courts of Justice Act on the basis that Chevron lacked assets in the jurisdiction and the plaintiffs had "no hope of success" in piercing the corporate veil of Chevron Canada. The plaintiffs appealed from the order imposing the stay. The defendants cross-appealed from the finding regarding jurisdiction.

The Ontario Court of Appeal allowed the appeal, setting aside the stay, and dismissed the cross-appeals. The defendants appealed.

The Supreme Court of Canada dismissed the appeal.

Conflict of Laws - Topic 8

General - Principle of comity - [See first, fourth and fifth Conflict of Laws - Topic 6606 ].

Conflict of Laws - Topic 603

Jurisdiction - General principles - Jurisdiction simpliciter (territorial competence) - [See all Conflict of Laws - Topic 6606 ].

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - To recognize and enforce a foreign judgment, the only prerequisite was that the foreign court had a real and substantial connection with the dispute's subject matter or that the traditional bases of jurisdiction were satisfied - Within the limits of the province, it was the act of service on the basis of a foreign judgment that granted an Ontario court jurisdiction over the defendants - There was no need to demonstrate a real and substantial connection between the dispute and the enforcing forum - To conclude otherwise would undermine the important values of order and fairness that underlay all conflicts rules - Cross-border transactions and interactions continued to multiply - As they did, comity required an increasing willingness by courts to recognize other states' acts - Jurisdiction was established with respect to Chevron - See paragraphs 24 to 27 and 75 to 77.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - The court had never imposed a requirement to prove a real and substantial connection between a defendant or the dispute and the province in actions to recognize and enforce foreign judgments - In the recognition and enforcement context, the real and substantial connection test operated simply to ensure that the foreign court from which the judgment originated had properly assumed jurisdiction over the dispute - Jurisdiction in Ontario was established when service was effected - There was no requirement or need to resort to the real and substantial connection test - Nothing in Van Breda et al. v. Village Resorts Ltd. (2012 S.C.C.) had changed that - Chevron's assertion that the court had to determine its own jurisdiction first by following the test articulated in Van Breda was misplaced - Van Breda did not analyze or modify the principles articulated to the recognition and enforcement of foreign judgments, the issue that was central to this appeal - See paragraphs 24 to 41.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - The distinct principles underlying actions for recognition and enforcement as opposed to actions at first instance were opposed to Chevron's position - The only purpose of an action for recognition and enforcement was to allow a pre-existing obligation to be fulfilled - This was a crucial difference from an action at first instance - The enforcing court's role was not one of substance, but of facilitation - The facts underlying the judgment were irrelevant, except as they related to potential defences to enforcement - The only important element was the foreign judgment, itself, and the legal obligation it had created - Further, enforcement was limited to measures that could only be taken within the jurisdiction's confines and in accordance with its rules - Any potential constitutional concerns that might emerge in conflict of laws cases did not arise in recognition and enforcement proceedings - Enforcement was limited to seizable assets in the jurisdiction - No constitutional concern about the legitimacy of the exercise of jurisdiction emerged - The purposes that underlay recognition and enforcement proceedings simply did not require proof of a real and substantial connection, whether for constitutional reasons or otherwise - See paragraphs 42 to 50.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - The distinct principles underlying actions for recognition and enforcement as opposed to actions at first instance were opposed to Chevron's position - This included that the notion of comity, which had consistently underlain actions for recognition and enforcement, militated in favour of generous enforcement rules - Legitimate judicial acts were to be respected and enforced, not sidetracked or ignored - The concepts of order and fairness in which comity was grounded were not affronted by rejecting Chevron's proposed extension of the real and substantial connection test - Order and fairness were protected by ensuring that a real and substantial connection existed between the foreign court and the underlying dispute - Nor was there any unfairness in judgment debtors having to defend against recognition and enforcement proceedings - See paragraphs 51 to 55.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - Requiring a defendant in recognition and enforcement proceedings to have a real and substantial connection with the enforcing court in the sense of being present or having assets in the province would undermine the concepts of order and fairness in which comity was grounded - In the globalized world and electronic age, requiring a judgment creditor to wait until the foreign debtor was present or had assets in the province would be to turn a blind eye to current economic reality - Many courts in common law jurisdictions had been hesitant to make the presence of assets a prerequisite to jurisdiction in recognition and enforcement proceedings - Further, most Canadian conflict of laws scholars supported the view that requiring a real and substantial connection through the defendant being present or having assets in the province was not necessary in a recognition and enforcement action - Facilitating comity and reciprocity called for assistance, not barriers - The principle of comity did not require the adoption of Chevron's submissions - See paragraphs 56 to 69.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada (the defendants) - Chevron asserted that jurisdiction to hear an action to recognize and enforce a foreign judgment was not established unless there was a "real and substantial connection" between the defendants or the dispute and Ontario - The Supreme Court of Canada rejected Chevron's argument - The experiences of other jurisdictions, convincing academic commentary and the fact that comparable statutory provisions existed in provincial legislation reinforced the court's approach - The court reviewed the relevant legislation, concluding that "to find in this case that there is no requirement of a real and substantial connection between the forum and the dispute in an action for recognition and enforcement would neither pervert the Ontario legislators' intentions, nor risk some other unforeseen outcome. Instead, such a finding would be respectful of the legislative choices already made by the province, while leaving open legal space in which it is free to develop its own conflict of laws rules, if it so chooses. This decision is limited to common law recognition and enforcement principles." - See paragraphs 70 to 74.

Conflict of Laws - Topic 6606

Foreign judgments - General - Recognition of judgment of foreign state - The plaintiffs were indigenous Ecuadorian villagers who asserted that Chevron Corp. had extensively polluted an area of Ecuador - The plaintiffs obtained a judgment in Ecuador against Chevron for $9.51 billion (US) in environmental and health tort claim damages - They sought to enforce the judgment in Canada against Chevron and its Canadian subsidiary, Chevron Canada - The Supreme Court of Canada rejected Chevron Canada's assertion that jurisdiction could not be established over it as it was a stranger to the original foreign judgment - Presence based jurisdiction was established on the basis of Chevron Canada's office in Ontario where it was served in juris - Where jurisdiction stemmed from the defendant's presence in the jurisdiction, there was no need to consider whether a real and substantial connection existed - If a defendant maintained a place of business in Ontario, it was reasonable to say that the Ontario courts had an interest in the defendant and the disputes in which it became involved - Because jurisdiction was established over Chevron Canada on traditional grounds, the court did not have to consider how jurisdiction might be established over a third party who was not present in and had not attorned to the jurisdiction of the Ontario courts but who was alleged to be capable of satisfying a foreign judgment debt - However, the court made several comments in that regard - See paragraphs 75 to 95.

Conflict of Laws - Topic 6661

Foreign judgments - Action on foreign judgment - General principles - [See all Conflict of Laws - Topic 6606 ].

Practice - Topic 5921

Judgments and orders - Enforcement of foreign judgments - General - [See all Conflict of Laws - Topic 6606 ].

Cases Noticed:

Aguinda v. Texaco Inc. (2002), 303 F.3d 470 (2d Cir.) (C.A.), refd to. [para. 5].

Chevron Corp. v. Donziger (2011), 768 F. Supp. 2d 581 (S.D.N.Y.), refd to. [para. 7].

Chevron Corp. v. Naranjo (2012), 667 F.3d 232 (2d Cir.), refd to. [para. 7].

Chevron Corp. v. Donziger (2014), 974 F. Supp. 2d 362 (S.D.N.Y.), refd to. [para. 7].

Van Breda et al. v. Village Resorts Ltd. et al., [2012] 1 S.C.R. 572; 429 N.R. 217; 291 O.A.C. 201; 2012 SCC 17, refd to. [para. 12].

Morguard Investments Ltd. et al. v. De Savoye, [1990] 3 S.C.R. 1077; 122 N.R. 81, refd to. [para. 13].

Beals v. Saldanha et al., [2003] 3 S.C.R. 416; 314 N.R. 209; 182 O.A.C. 201; 2003 SCC 72, refd to. [para. 13].

Pro Swing Inc. v. Elta Golf Inc., [2006] 2 S.C.R. 612; 354 N.R. 201; 218 O.A.C. 339; 2006 SCC 52, refd to. [para. 25].

Hunt v. Lac d'Amiante du Québec ltée et al., [1993] 4 S.C.R. 289; 161 N.R. 81; 37 B.C.A.C. 161; 60 W.A.C. 161, refd to. [para. 47].

Hilton v. Guyot (1895), 159 U.S. 113, refd to. [para. 51].

R. v. Spencer, [1985] 2 S.C.R. 278; 62 N.R. 81; 11 O.A.C. 207, refd to. [para. 51].

Tolofson v. Jensen and Tolofson, [1994] 3 S.C.R. 1022; 175 N.R. 161; 77 O.A.C. 81; 51 B.C.A.C. 241; 84 W.A.C. 241, refd to. [para. 52].

BNP Paribas (Canada) v. Mécs, [2002] O.T.C. 505; 60 O.R.(3d) 205 (Sup. Ct.), refd to. [para. 57].

Tasarruf Mevduati Sigorta Fonu v. Demirel, [2007] 1 W.L.R. 2508 (Eng. & Wales C.A., Civil Div.), refd to. [para. 59].

Yukos Capital S.A.R.L. v. OAO Tomskneft VNK, [2014] I.E.H.C. 115, refd to. [para. 60].

Lenchyshyn v. Pelko Electric Inc. (2001), 723 N.Y.S.2d 285 (App. Div.), refd to. [para. 61].

Abu Dhabi Commercial Bank PJSC v. Saad Trading, Contracting and Financial Services Co. (2014), 986 N.Y.S.2d 454 (App. Div.), refd to. [para. 61].

Haaksman v. Diamong Offshore (Bermuda) Ltd. (2008), 260 S.W.3d 476 (Tex. App.), refd to. [para. 61].

Pure Fishing Inc. v. Silver Star Co. (2002), 202 F. Supp.2d 905 (N.D. Iowa), refd to. [para. 61].

Electrolines Inc.v . Prudential Assurance Co. (2004), 677 N.W.2d 874 (Mich. C.A.), refd to. [para. 62].

Base Metal Trading Ltd. v. OJSC Novokuznetsky Aluminum Factory (2002), 283 F.3d 208, cert. denied (2002), 537 U.S. 822, refd to. [para. 62].

CSA8-Garden Village LLC v. Dewar, [2013] O.T.C. Uned. 6229; 369 D.L.R.(4th) 125; 2013 ONSC 6229, refd to. [para. 67].

Canada Post Corp. v. Lépine, [2009] 1 S.C.R. 549; 387 N.R. 91; 2009 SCC 16, refd to. [para. 72].

Salomon v. Salomon & Co., [1897] A.C. 22, refd to. [para. 80].

Ontario v. Rothmans Inc. et al. (2013), 305 O.A.C. 261; 115 O.R.(3d) 561; 2013 ONCA 353, refd to. [para. 80].

Muscutt et al. v. Courcelles et al. (2002), 160 O.A.C. 1; 60 O.R.(3d) 20 (C.A.), refd to. [para. 82].

Wilson v. Hull (1995), 174 A.R. 81; 102 W.A.C. 81 (C.A.), refd to. [para. 85].

Ingersoll Packing Co. v. New York Central & Hudson River Railway Co. (1918), 42 O.L.R. 330 (S.C. App. Div), refd to. [para. 85].

Adams v. Cape Industries Plc., [1990] 1 Ch. 433, refd to. [para. 85].

Incorporated Broadcasters Ltd. et al. v. Canwest Global Communications Corp. et al. (2003), 169 O.A.C. 1; 63 O.R.(3d) 431 (C.A.), refd to. [para. 86].

Prince et al. v. ACE Aviation Holdings Inc. et al., [2013] O.T.C. Uned. 2906; 115 O.R.(3d) 721; 2013 ONSC 2906, refd to. [para. 86].

Prince et al. v. ACE Aviation Holdings Inc. et al. (2014), 319 O.A.C. 163; 120 O.R.(3d) 140; 2014 ONCA 285, refd to. [para. 86].

Abdula v. Canadian Solar Inc. et al., [2011] O.T.C. Uned. 5105; 92 B.L.R.(4th) 324; 2011 ONSC 5105, affd. (2012), 289 O.A.C. 226; 110 O.R.(3d) 256; 2012 ONCA 211, refd to. [para. 86].

Charron v. Banque provinciale du Canada, [1936] O.W.N. 315 (H.C.J.), refd to. [para. 86].

Patterson et al. v. EM Technologies Inc. et al., [2013] O.T.C. Uned. 5849; 2013 ONSC 5849, refd to. [para. 87].

Aegon Capital Management Inc. et al. v. BCE Inc. et al., [2008] 3 S.C.R. 560; 383 N.R. 119; 2008 SCC 69, refd to. [para. 95].

BCE Inc. v. 1976 Debentureholders - see Aegon Capital Management Inc. et al. v. BCE Inc. et al.

Authors and Works Noticed:

Black, Vaughan, Enforcement of Judgments and Judicial Jurisdiction in Canada (1989), 9 Oxford J. Legal Stud. 547, generally [para. 29].

Black, Vaughan, Pitel, Stephen G.A. and Sobkin, Michael, Statutory Jurisdiction: An Analysis of the Court Jurisdiction and Proceedings Transfer Act (2012), pp. 146, 147 [para. 73].

Blom, Joost, New Ground Rules for Jurisdictional Disputes: The Van Breda Quartet (2013), 53 Can. Bus. L.J. 1, p. 12 [para. 89].

Brand, Ronald A., Federal Judicial Center International Litigation Guide: Recognition and Enforcement of Foreign Judgments (2013), 74 U. Pitt. L. Rev. 491, generally [para. 61]; p. 506 [para. 62].

Briggs, Adrian, The Conflict of Laws (3rd Ed. 2013), Oxford Univ. Press, pp. 52, 53 [para. 77].

Castel, J.-G., Introduction to Conflict of Laws (4th Ed. 2002), p. 83 [para. 83].

Collins, Lawrence, Dicey and Morris on the Conflict of Laws, (13th Ed. 2000), vol. 1, rule 35, pp. 474, 475 [para. 35].

Monestier, Tanya J., A Real and Substantial Mess: The Law of Jurisdiction in Canada (2007), 33 Queen's L.J. 179, pp. 192 [para. 69]; 449 [para. 83].

Monestier, Tanya J., Jurisdiction and the Enforcement of Foreign Judgments (2014), 42 Adv. Q. 107, p. 110 [para. 34].

Perell, Paul M., and Morden, John W., The Law of Civil Procedure in Ontario (2nd Ed. 2014), paras. 11.177 [para. 43]; 11.181 [para. 65].

Pitel, Stephen G.A., and Dusten, Cheryl, D., Lost in Transition: Answering the Questions Raised by the Supreme Court of Canada's New Approach to Jurisdiction (2006), 85 Can. Bar. Rev. 61, p. 69 [para. 83].

Pitel, Stephen G.A., and Rafferty, Nicholas S., Conflict of Laws (2010), pp. 53 [paras. 29, 83]; 159, 160 [para. 66].

Walker, Janet, Castel & Walker: Canadian Conflict of Laws (6th Ed. 2005) (2015 Looseleaf Update, Release 50), pp. 11-52 [para. 46]; 14-1 [paras. 64, 68]; 14-11 [para. 46].

Watson, Garry D., and Au, Frank, Constitutional Limits on Service Ex Juris: Unanswered Questions from Morguard (2000), 23 Adv. Q. 167, p. 205 [para. 69].

Counsel:

Clarke Hunter, Q.C., Anne Kirker, Q.C., and Robert Frank, for the appellant, Chevron Corporation;

Benjamin Zarnett, Suzy Kauffman and Peter Kolla, for the appellant, Chevron Canada Limited;

Alan J. Lenczner, Q.C., Brendan F. Morrison and Chris J. Hutchison, for the respondents;

Murray Klippenstein, Renu Mandhane and W. Cory Wanless, for the interveners, the International Human Rights Program at the University of Toronto Faculty of Law, MiningWatch Canada and the Canadian Centre for International Justice;

A. Dimitri Lascaris and James Yap, for the intervener, the Justice and Corporate Accountability Project.

Solicitors of Record:

Norton Rose Fulbright Canada, Calgary, Alberta and Toronto, Ontario, for the appellant, Chevron Corporation;

Goodmans, Toronto, Ontario, for the appellant, Chevron Canada Limited;

Lenczner Slaght Royce Smith Griffin, Toronto, Ontario; Conway Baxter Wilson, Ottawa, Ontario, for the respondents;

Klippensteins, Toronto, Ontario; University of Toronto, Toronto, Ontario, for the interveners, the International Human Rights Program at the University of Toronto Faculty of Law, MiningWatch Canada and the Canadian Centre for International Justice;

Siskinds, London, Ontario, for the intervener, the  Justice   and   Corporate  Accountability Project.

This appeal was heard on December 11, 2014, by McLachlin, C.J.C., Abella, Rothstein, Cromwell, Karakatsanis, Wagner and Gascon, JJ., of the Supreme Court of Canada. On September 4, 2015, Gascon, J., delivered the following reasons for judgment in both official languages for the court.

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1 practice notes
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    • Manitoba Court of Queen's Bench of Manitoba (Canada)
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    ...- Registration or enforcement - Defences - [See Conflict of Laws - Topic 6606 ]. Cases Noticed: Yaiguaje et al. v. Chevron Corp. et al. (2015), 474 N.R. 1; 335 O.A.C. 201; 2015 SCC 42, consd. [para. Morguard Investments Ltd. et al. v. De Savoye, [1990] 3 S.C.R. 1077; 122 N.R. 81, refd to. [......
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