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SCC Expands The Duty Of Honest Performance: Silence Or Non-Disclosure Can Now Also Constitute A Breach - Litigation, Mediation & Arbitration

Bhasin”). Many had hoped that the decision would shed light on the scope of the duty of good faith and honest performance recognized in Bhasin, and provide clear guidance to lower courts and commercial parties on their contractual obligations. However, the decision which resulted in a 5-3-1 split across the court (Kasirer J writing for the majority, Brown J concurring, and Côté J in dissent) may add further uncertainty to the jurisprudence around obligations of good faith. While the majority of the Court agreed that the respondent, a group of condominium corporations known as Baycrest (“Baycrest”), had breached its duty of honest

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