Oliveira v. Manitoba Public Insurance Corporation

Oliveira v. Manitoba Public Insurance Corporation

The respondent's undertaking not to raise limitation if the action proceeds in Manitoba removed limitation expiry from the forum analysis, the motion judge properly weighed the remaining factors and correctly concluded Manitoba is the appropriate forum; the Ontario proceeding must be stayed and the appeal dismissed.

Source-derived case information.

Citation
2009 ONCA 435
Parties
Appellant: Arlindo Oliveira; Respondent: Manitoba Public Insurance Corporation
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
26 May 2009
Procedural Posture
Civil Appeal (forum Conveniens/ Stay Application) / Court of Appeal Endorsement Disposing of Appeal From Motion Judge's Stay Order
Outcome
Appeal dismissed; Ontario proceedings stayed in favour of Manitoba forum; costs awarded to respondent.
Legal Topics
Forum Conveniens, Stay of Proceedings, Limitation Period as Factor, Choice of Forum
Source Language
en
Civil Procedure Private International Law Limitation Law Forum Conveniens Stay of Proceedings Limitation Period as Factor Choice of Forum

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Parties

Arlindo Oliveira

Appellant

Manitoba Public Insurance Corporation

Respondent

Procedural Posture

Civil Appeal (forum Conveniens/ Stay Application) / Court of Appeal Endorsement Disposing of Appeal From Motion Judge's Stay Order

  1. 1 Whether Manitoba is the proper forum under forum conveniens principles
  2. 2 Whether expiry of limitation period should influence forum conveniens analysis
  3. 3 Whether the Ontario proceeding should be stayed

Ratio Decidendi

The respondent's undertaking not to raise limitation if the action proceeds in Manitoba removed limitation expiry from the forum analysis, the motion judge properly weighed the remaining factors and correctly concluded Manitoba is the appropriate forum; the Ontario proceeding must be stayed and the appeal dismissed.

Court Disposition

Appeal dismissed; Ontario proceedings stayed in favour of Manitoba forum; costs awarded to respondent.

Orders

  • Ontario proceeding stayed
  • Matter to proceed in Manitoba