Dhanna v. Ontario (Ministry of Labour)

Dhanna v. Ontario (Ministry of Labour)

The settlement agreement's escrow clause was construed to mean the mortgage would not create an interest in land unless and until default occurred; because there was no default the bank had no interest to assign and post-agreement evidence could not override the agreement's plain terms, therefore the appeal was...

Source-derived case information.

Citation
2009 ONCA 50
Parties
Appellant: Harripaul Dhanna; Respondent: Ontario Ministry of Labour
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
20 January 2009
Procedural Posture
Civil / Court of Appeal Judgment on Appeal From Superior Court
Outcome
Appeal dismissed
Legal Topics
Settlement Agreement, Escrow, Mortgage Assignment, Intention of Parties, Priority Dispute, Costs
Source Language
en
Contract Law Property Law Civil Procedure Settlement Agreement Escrow Mortgage Assignment Intention of Parties Priority Dispute +1 more

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Parties

Harripaul Dhanna

Appellant

Ontario Ministry of Labour

Respondent

Procedural Posture

Civil / Court of Appeal Judgment on Appeal From Superior Court

  1. 1 Meaning and effect of the term "will be held in escrow" in a settlement agreement
  2. 2 Whether a mortgage created an interest in land prior to a default and thus was assignable
  3. 3 Admissibility and weight of post-agreement statements and actions to prove parties' intention

Ratio Decidendi

The settlement agreement's escrow clause was construed to mean the mortgage would not create an interest in land unless and until default occurred; because there was no default the bank had no interest to assign and post-agreement evidence could not override the agreement's plain terms, therefore the appeal was dismissed.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Costs fixed at $5,000 inclusive of G.S.T. and disbursements