Coutu Gold Mines Company Limited v. Ontario

Coutu Gold Mines Company Limited v. Ontario

The appeal was dismissed because the 2013 claim sought the same relief and raised the same issues as the appellant's 2008 and 2010 actions which were previously dismissed, so res judicata and abuse of process barred the re-litigation; further, the Coutu Gold Mines Limited Act, 2012 expressly preserved the Crown's...

Source-derived case information.

Citation
2014 ONCA 684
Parties
Appellant: Coutu Gold Mines Company Limited; Respondent: Her Majesty the Queen in Right of Ontario
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
3 October 2014
Procedural Posture
Civil / Appeal From Motion Judge's Dismissal Order
Outcome
Appeal dismissed.
Legal Topics
Res Judicata, Abuse of Process, Limitation Periods, Forfeiture of Mining Rights, Statutory Interpretation
Source Language
en
Civil Procedure Property Law Administrative Law Statutory Interpretation Res Judicata Abuse of Process Limitation Periods Forfeiture of Mining Rights

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Parties

Coutu Gold Mines Company Limited

Appellant

Her Majesty the Queen in Right of Ontario

Respondent

Procedural Posture

Civil / Appeal From Motion Judge's Dismissal Order

  1. 1 Whether the 2013 action is barred by res judicata because it raises the same issues and seeks the same relief as prior 2008 and 2010 actions
  2. 2 Whether the doctrine of abuse of process bars the 2013 action
  3. 3 Whether limitation periods preclude the claim

Ratio Decidendi

The appeal was dismissed because the 2013 claim sought the same relief and raised the same issues as the appellant's 2008 and 2010 actions which were previously dismissed, so res judicata and abuse of process barred the re-litigation; further, the Coutu Gold Mines Limited Act, 2012 expressly preserved the Crown's status regarding forfeited mining rights and did not revive or affect rights forfeited after dissolution; no error in the motion judge's dismissal and no basis to permit a new legal theory to avoid res judicata.

Court Disposition

Appeal dismissed.

Orders

  • Appeal dismissed and motion judge's dismissal affirmed
  • Appellant to pay respondent $1,000 in costs inclusive of disbursements and all applicable taxes