McKenna v. Marshall

McKenna v. Marshall

The Farm Debt Mediation Act's notice provision in s.21 must be served before enforcement proceedings may be taken and this entitlement is not conditioned on showing insolvency; consequently, proceedings following failure to serve the s.21 notice are null and void under s.22; the contempt provisions were set aside...

Source-derived case information.

Citation
C40991
Parties
Plaintiff/respondent in Appeal: George McKenna; Defendant/appellant in Appeal: Anthony Harold Marshall; Defendant/appellant in Appeal: Cathy Marshall
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
13 May 2004
Procedural Posture
Civil Appeal / Appeal From Superior Court Judgment; Decision on Appeal
Outcome
Appeal allowed; order of Harris J. set aside; respondent's motion for summary judgment dismissed; contempt provisions set aside; specified costs directions issued.
Legal Topics
Notice Under S.21, Nullity of Proceedings Under S.22, Summary Judgment, Purging Contempt, Costs Award
Source Language
english
Farm Debt Mediation Act Civil Procedure Contempt of Court Enforcement of Security Costs Notice Under S.21 Nullity of Proceedings Under S.22 Summary Judgment +2 more

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Parties

George McKenna

Plaintiff/respondent in Appeal

Anthony Harold Marshall

Defendant/appellant in Appeal

Cathy Marshall

Defendant/appellant in Appeal

Procedural Posture

Civil Appeal / Appeal From Superior Court Judgment; Decision on Appeal

  1. 1 Whether s.21 of the Farm Debt Mediation Act requires service of notice before enforcement proceedings may proceed
  2. 2 Whether a party must demonstrate insolvency to rely on the s.21 notice provision
  3. 3 Whether proceedings following failure to serve the s.21 notice are null and void under s.22

Ratio Decidendi

The Farm Debt Mediation Act's notice provision in s.21 must be served before enforcement proceedings may be taken and this entitlement is not conditioned on showing insolvency; consequently, proceedings following failure to serve the s.21 notice are null and void under s.22; the contempt provisions were set aside because they were made without prior notice and have been purged by payment of costs; the motion for summary judgment was therefore dismissed and the order of the trial judge set aside.

Court Disposition

Appeal allowed; order of Harris J. set aside; respondent's motion for summary judgment dismissed; contempt provisions set aside; specified costs directions issued.

Orders

  • Order of Harris J. set aside
  • Respondent's motion for summary judgment dismissed