CITATION: Traders General Insurance Company v. Rumball, 2025 ONSC 779
DIVISIONAL COURT FILE NO.:301/24 DATE: 20250214
ONTARIO SUPERIOR COURT OF JUSTICE
DIVISIONAL COURT
BACKHOUSE, FAIETA, RYAN BELL JJ.
BETWEEN:
TRADERS GENERAL INSURANCE COMPANY
Eric K. Grossman and Rebecca J. Brown Greer, for the Applicant
Applicant
– and –
SHELLEY RUMBALL
Respondent
– and –
LICENCE APPEAL TRIBUNAL
Fabio Longo and Bryan Fromstein, for the Respondent Shelley Rumball
Morgana Kellythorne, for the Respondent Licence Appeal Tribunal
Respondent
HEARD: February 3, 2025
rEASONS FOR DECISION
FAIETA J.
[1] The Applicant, Traders General Insurance Company (“Traders”), brings this application for judicial review of:
(a) the Preliminary Issue Decision of Christopher A. Ferguson, an Adjudicator with the Licence Appeal Tribunal (the “Tribunal”), dated February 5, 2018 (“the Preliminary Issue Decision”). The Tribunal found that the Respondent Shelley Rumball is not barred from appealing Traders’ denial of her claim for income replacement benefits (“IRBs”) by the two year limitation period under section 56 of the Statutory Accident Benefits Schedule – Effective September 1, 2010, O. Reg. 34/10, as amended (“SABS”) because Traders’ letter dated March 4, 2015 was not a clear and unequivocal denial of IRBs.
(b) the Reconsideration Decision of Associate Chair Batty, dated May 8, 2019 (the “Reconsideration Decision”), in which the Associate Chair refused to extend the time for filing Traders’ request for reconsideration of the Preliminary Issue Decision and, accordingly, dismissed the request for reconsideration.
[2] For the reasons set out below, this application for judicial review is dismissed.
BACKGROUND
[3] On December 28, 2014, Ms. Rumball was involved in an automobile accident where she was rear-ended by a pickup truck. On January 23, 2015, Ms. Rumball submitted a Disability Certificate (OCF-3) which stated that she had suffered injuries to her neck and back as a result of the accident and had not returned to work as an educational assistant. A health professional certified that Ms. Rumball had suffered a whiplash associated disorder and a lumbar spine strain. He also stated that Ms. Rumball was only able to return to work on modified hours and/or duties.
[4] On February 23, 2015, Ms. Rumball submitted an Employer’s Confirmation Form (OCF-2) which confirmed that her last day of work was December 19, 2014.
Traders’ March 4, 2015 letter
[5] By letter dated March 4, 2015, an insurance adjuster at Traders notified Ms. Rumball that her IRBs would be terminated as she had returned to work (the “Letter”). The Letter states:
EXPLANATION OF BENEFITS
Details
Amount Claimed
Amount Payable
Interest Payable
Income Replacement Benefits: no longer eligible
$380.28/week
Reasons for our decision:
As per Section 37(2)(e) of the Statutory Accident Benefits Schedule (SABS), we are therefore terminating your IRB effective February 25, 2015, as you have resumed your pre-accident employment duties. Should you be off work again due to the injuries sustained as a result of the subject motor vehicle accident, we would require an updated Disability Certificate (OCF-3) to determine your eligibility. Per Section 36(2)(3) of the SABS an applicant for a specified benefit shall submit a completed Disability Certificate (OCF-3) that indicates you meet the disability test. There is no entitlement to benefits for any period before the updated Disability Certificate is submitted.
Should you wish to dispute this decision please refer to the Applicant’s Rights to Dispute on the following pages. Your first step is to apply for mediation. Should you require information regarding your rights to dispute or the appropriate forms please do not hesitate to contact the writer. Please ensure that you initiate your dispute within TWO YEARS.
Your right to dispute:
Under the Insurance Act, if your claim for Statutory Accident Benefits has been reduced or denied by your insurer, you have a right to dispute your insurer’s determination. There are a number of steps you can take to try and resolve the dispute.
STEP 1: MEDIATION
If you are unable to resolve your dispute by speaking to your adjuster, you may apply to mediate your dispute through the Financial Services Commission of Ontario (FSCO) within two years of your insurer’s refusal to pay, or reduction of a benefit. …
STEP 2: ARBITRATION, LAWSUIT OR EVALUATION
If mediation does not resolve the dispute, you have the right to:
(i) apply for the appointment of an arbitrator at FSCO, or
(ii) commence a lawsuit in court, or
(iii) if you and your insurer both agree, you may request a neutral evaluation at FSCO before proceeding to arbitrate or commence a lawsuit in court. …
However, you CANNOT arbitrate, commence a lawsuit or request a neutral evaluation UNLESS:
(i) you proceeded with mediation; AND
(ii) the mediation failed.
WARNING: TWO YEAR TIME LIMIT
You have TWO YEARS from the date of your insurer’s refusal to pay, or reduction of a benefit, to arbitrate or commence a lawsuit in court. You may have longer than two years if the arbitration or lawsuit is commenced 90 days from the date the mediator provides his or her mediation report, or within 30 days from the date the neutral evaluator provides his or her report.
Should you have any questions or require assistance please do not hesitate to contact the writer at the number below. [Bold in original. Underlining added for emphasis.]
Traders’ June 15, 2016 letter
[6] Ms. Rumball states that she had to stop working on May 31, 2015 as a result of symptoms that arose from the motor vehicle accident.
[7] On June 15, 2016, Ms. Rumball contacted Traders to notify them that she had been unable to work because of her injuries. That same day, Traders responded with a letter that outlined next steps:
This is further to our telephone conversation this afternoon.
You stated that your medical practitioners support the need for ongoing therapy because of your pain complaints.
You also stated that you have been unable to work after May 31, 2015 because of your accident related injuries.
To assist us with further addressing your claim, we are enclosing Permission to Disclose Health Information form (OCF-5) and a Release for OHIP records which we ask that you sign and return to us so that we may request a copy of your clinical notes and records as well as your OHIP records from December 2013 to present date.
We are also requesting a copy of your income tax records with Notice of Assessment for 2015. …
If you disagree with our assessment of your file and wish to dispute it, file an application with the License Appeal Tribunal. Please review the remainder of this letter for more details.
Statutory Accident Benefits claim – your right to dispute
Under the Insurance Act, you have a right to dispute our decision if we have reduced or denied your claim for Statutory Accident Benefits. The License Appeal Tribunal – Automobile Accident Benefits Service (LAT – AABS) offers dispute resolution services to help settle accident benefits disputes within two years of the date of reduction or denial.
Two year time limit
It’s important to note you must file an application with the LAT – AABS within two years from the time we reduced or denied your claim for accident benefits. If you don’t apply within that time frame, you will lose the right to dispute the determination. … [Emphasis added]
Should you have any questions please do not hesitate to contact the writer.
Ms. Rumball’s Application to the Tribunal
[8] On June 13, 2017, Ms. Rumball obtained a second OCF-3 disability certificate.
[9] On July 17, 2017, Ms. Rumball delivered an Application by an Injured Person for Auto Insurance Dispute Resolution under the Insurance Act to the Tribunal on the grounds that the insurer withheld or denied IRBs.
[10] On August 22, 2017, the Tribunal delivered notice to the parties that a Case Conference would be held. In its response, Traders stated that it intended on raising the following preliminary issue at the Case Conference:
IRB claim is barred by statute of limitations and must be dismissed.
The statute of limitations begins to run from the date of denial, which was clearly and unequivocally communicated to the claimant on March 4, 2015. There is no element of reasonable excuse for delayed dispute, and the Superior Court, Court of Appeal, and Supreme Court of Canada have universally held that the 2-year limitation period for AB disputes is absolute. …
By way of Explanation of Benefits dated March 4, 2015, Traders General informed the claimant that it was terminating her IRB as of February 25, 2015. This was the date that the claimant returned to work. The denial is clear and unequivocal, and started the limitation period.
The claimant did not dispute the termination of IRB within 2 years of the date of denial, and her entitlement to dispute expired on March 4, 2017. This claim is wholly barred and must be dismissed.
[11] On October 5, 2017, a Case Conference was held. Counsel for Ms. Rumball submitted that Traders’ letter dated March 4, 2015 “… left room for the applicant to re-apply for IRB benefits should her condition change”. On consent of the parties, a preliminary issue written hearing was scheduled to decide whether Ms. Rumball’s IRB claim was statute barred pursuant to s. 56(1) of the SABS.
The Preliminary Issue Decision
[12] On February 5, 2018, the Preliminary Issue Decision was released. The Tribunal concluded that Traders’ letter dated March 4, 2015 was not a clear and unequivocal denial of Ms. Rumball’s claim for IRBs based on the following reasons.
[13] At paragraph 25, the Tribunal stated:
I interpret it as clearly informing the applicant that she remains eligible for further IRBs if she has to leave work due to her accident-related injuries and submits an updated OCF-3 so that the insurer can determine her eligibility.
It lacks any statement that the insurer would only consider an updated OCF-3 if it were sent within two years of the letter.
The letter’s notice of limitation period on the applicant’s right to dispute its termination of IRBs was equivocal because it referred to “this decision” [emphasis mine]. I find that “this decision” could reasonably be interpreted to:
a. Include the stipulation by the insurer that it would reconsider her IRBs upon submission of an updated OCF-3, and
b. Exclude any further “s. 11 decision” by the respondent made with respect to an updated OCF-3 and accompany documents.
The wording of the bold-typed paragraph on page three of the letter, warning of a two-year limit for commencing arbitration (i.e. an appeal), does not reinforce the respondent’s interpretation that it has set the limitation period running on future IRB claims.
As the result of my observations in subparagraphs 1-4, I find that the letter could reasonably lead the applicant to believe that her options with respect to the IRBs were being kept open in case her circumstances changed – and not to believe that it had denied her eligibility for IRBs with finality.
I am persuaded that the ambiguity I see in the denial notice should be interpreted in favour of the insured, applying the contra proferentum rule that laws purporting to be consumer protection should be interpreted generously in favour of consumers, a widely understood principle in consumer and insurance contract law, articulated in Balzer and confirmed by the Supreme Court of Canada in numerous cases, including Smith.
[14] At paragraph 29, the Tribunal further stated:
The respondent contends that a temporary return to work as defined by s. 11 of the Schedule “does not operate to reset the limitation period”. True as that may be, that is not the issue here. The respondent does not explain how its argument overcomes the requirement for a denial to be clear and unequivocal. The cases it cites, such as Haldenby, do not provide me with an answer on this issue.
[15] Accordingly, the Tribunal directed that Ms. Rumball’s application proceed to be determined on its merits.
Appeal to Divisional Court
[16] On February 28, 2019, an appeal by Traders from the Preliminary Issue Decision to the Divisional Court was dismissed as premature given that the merits of Ms. Rumball’s claim had not been determined: Traders General Insurance Company v. Rumball, 2019 ONSC 1412.
The Reconsideration Decision
[17] On March 20, 2019, Traders requested a reconsideration of the Preliminary Issue Decision.
[18] On May 8, 2019, the Tribunal’s Reconsideration Decision dismissed Traders’ request for reconsideration as it was filed far beyond the 21-day deadline for such requests.
Hearing on the merits
[19] A hearing on the merits of Ms. Rumball’s application was heard. On July 24, 2020, Ms. Rumball was awarded 104 weeks of IRBs. However, her claim for IRBs beyond 104 weeks was dismissed on the basis that her injuries did not meet the statutory test.
[20] On August 18, 2020, Traders’ second request for reconsideration of the Preliminary Issue Decision was dismissed by the Tribunal for being filed beyond the 21-day deadline and for being an abuse of process given that its request for reconsideration had already been dismissed once.
Appeal and Cross-appeal to Divisional Court
[21] Traders appealed the Preliminary Issue Decision to the Divisional Court, arguing that the Tribunal erred in law by holding that the Letter was not clear and unequivocal. Ms. Rumball cross-appealed from the Tribunal decision dated July 24, 2020, and the Tribunal’s reconsideration decision dated February 3, 2021, on the basis that the Tribunal applied the wrong legal test in dismissing Ms. Rumball’s claim for IRBs from December 29, 2016 onwards.
[22] The Divisional Court dismissed Traders’ second appeal of the Preliminary Issue Decision because the determination of whether the Letter was a “clear and unequivocal” termination of IRBs was a question of mixed fact and law, rather than a question of law, and not subject to appeal. Ms. Rumball’s cross-appeal on the post-104 IRBs test was also dismissed: see Traders General Insurance Company v. Rumball, 2022 ONSC 7215, at paras. 31, 62.
[23] In respect of Traders’ appeal, the Divisional Court went on to state that the Tribunal’s finding that the Letter was ambiguous was an “entirely plausible interpretation”. The Divisional Court stated:
32 The finding that the letter was ambiguous, that it allowed for the reintroduction of the claim with the provision of a further Disability Certificate while limiting to two years any appeal of the refusal to extend the claim as it stood at the time, is an entirely plausible interpretation of the letter. This understanding of the letter has the decided advantage of accounting logically for each of the provisions found in it. Otherwise, the insured is left to understand that if there is a change in circumstances leading to a reason to reintroduce the claim, it has to happen within two years. If this is the situation, it should be, as the decision of the Licence Appeal Tribunal suggests, clearly explained.
33 Counsel for Traders submits that this fails to deal with a significant number of decisions from the Court of Appeal which establish that there can only be one claim. With a proper termination in place, there is no ability to start again. The insured is required to appeal within two years. The problem is that the termination had to be "clear and unequivocal". In this case the LAT found that it was not. The appeal by Traders is therefore dismissed. [Emphasis added]
[24] On July 5, 2023, the Ontario Court of Appeal dismissed Traders’ motion for leave to appeal and granted Ms. Rumball’s motion for leave to appeal on the post-104 IRB test.
The Application for Judicial Review
[25] On September 16, 2024, Traders’ motion to extend the time to commence this application for judicial review in respect of the Preliminary Issue Decision and the Reconsideration Decision was granted. In Traders General Insurance Company v. Rumball, 2024 ONSC 5011, at paras. 5 and 12, Matheson J. stated:
This motion arises in highly unusual circumstances. The Final LAT Decision was the subject of an appeal and cross-appeal to this Court. The limitation period issue was the subject of the appeal and was dismissed because it was not a question of law. It was a question of mixed fact and law. There was therefore no right of appeal. The cross-appeal related to the denial of post-104 IRBs. It was also dismissed. The Court of Appeal denied leave from the decision on the appeal but granted leave from the decision on the cross-appeal. Upon being advised of this motion, the Court of Appeal vacated the hearing date regarding the cross-appeal pending these proceedings. …
This is an unusual case. Without the outstanding appeal hearing at the Court of Appeal, arising from the same Final LAT Decision and about the same benefits (IRBs), I would not grant the motion.
STATUTORY FRAMEWORK
[26] The Insurance Act, R.S.O. 1990, c. I.8 (the “Insurance Act”) and the SABS establish Ontario’s no-fault accident benefits regime. This regime requires that every automobile insurance policy in Ontario provide its holder with access to certain benefits in the event of a motor vehicle accident, regardless of fault. Pursuant to s. 268(1) of the Insurance Act, all automobile polices in Ontario include the benefits provided in the SABS. A person who is injured in a motor vehicle accident may then claim the SABS’s benefits from their insurer.
[27] The Tribunal has exclusive jurisdiction under s. 280(1) of the Insurance Act to resolve any disputes in respect of an insured person’s entitlement to statutory accident benefits or in respect of the amount of statutory accident benefits to which an insured person is entitled. Further, s. 280(3) precludes an insured person from commencing an action for SABS; the only option is an application to the Tribunal. A decision of the Tribunal made under the Insurance Act may be appealed to the Divisional Court on a question of law alone: See Licence Appeal Tribunal Act, 1999, S.O. 1999, c. 12, Sched. G., ss. 11(1), (6).
[28] An insurer is required to pay IRBs to an insured person who sustains an impairment as a result of an accident if the insured person was employed at the time of the accident and, as a result of and within 104 weeks after the accident, suffers a substantial inability to perform the essential tasks of that employment: SABS, s. 5(1)1(i).
[29] Once eligibility for IRBs is established, IRBs are not payable after the first 104 weeks of disability unless the insured person suffers a complete inability to engage in any form of employment or self-employment for which they are reasonably suited by their education, training or experience: SABS, s. 6(1).
[30] If an insurer refuses to pay a benefit or reduces the amount of a benefit that a person is receiving, the insurer shall provide the person with a written notice advising the person of his or her right to dispute the refusal or reduction: SABS, s. 54.
[31] An application under subsection 280(2) of the Insurance Act in respect of a benefit shall be commenced within two years after the insurer’s refusal to pay the amount claimed: SABS, s. 56.
[32] In addition to the right of appeal to the Divisional Court on questions of law, a party may apply for judicial review of a Tribunal decision: Judicial Review Procedure Act, R.S.O. 1990, c. J.1, s. 2(1). An application for judicial review for questions of fact or mixed fact and law is not precluded by the existence of a right of appeal limited to questions of law. However, the court must determine whether judicial review is appropriate and, if it is not, may refuse to hear the application on its merits or may refuse to grant a remedy: Yatar v. TD Insurance Meloche Monnex, 2024 SCC 8, 489 D.L.R. (4th) 191, at paras. 3, 47, 49, 54.
ISSUES
[33] This application for judicial review raises the following issues:
(1) What is the standard of review?
(2) Was the Preliminary Issue Decision unreasonable?
(3) Should the Reconsideration Decision be set aside for being procedurally unfair?
ISSUE #1: WHAT IS THE STANDARD OF REVIEW?
[34] There is a presumption that reasonableness is the standard of review where a court reviews the merits of an administrative decision: Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, [2019] 4 S.C.R. 653 at para. 10.
[35] There is no dispute that the standard of review from a decision of the Tribunal on a question of mixed fact and law is reasonableness. The meaning of this standard was explained in Vavilov, at para. 15, as follows:
In conducting a reasonableness review, a court must consider the outcome of the administrative decision in light of its underlying rationale in order to ensure that the decision as a whole is transparent, intelligible and justified. What distinguishes reasonableness review from correctness review is that the court conducting a reasonableness review must focus on the decision the administrative decision maker actually made, including the justification offered for it, and not on the conclusion the court itself would have reached in the administrative decision maker's place.
ISSUE #2: WAS THE PRELIMINARY ISSUE DECISION UNREASONABLE?
[36] An insurer must provide “clear and unequivocal” notice denying or cancelling the insured’s benefits to trigger the two-year limitation period: Sietzema v. Economical Mutual Insurance Company, 2014 ONCA 111, 118 O.R. (3d) 713, at para. 13, leave to appeal refused, 2014 68702 (SCC). Given the consumer protection purpose of the Insurance Act and the SABS, such notice must be in “…straightforward and clear language, directed towards an unsophisticated person”: Smith v. Co-operators General Insurance Co., 2002 SCC 30, [2002] 2 S.C.R. 129, at para. 14.
[37] Traders submits that the Tribunal misapplied this test and that its Letter was sufficiently clear to allow Ms. Rumball to decide whether she wished to challenge the termination of IRBs. It states, at paras. 53 and 54 of its factum:
If Ms. Rumball had stopped working again as a result of the accident after February 25, 2015, she was fully capable of challenging Traders’ termination of IRB through dispute resolution within two years. The process and time limit was explained to her … . She did not do so. Even if, as Ms. Rumball argued at the preliminary issue hearing, Traders “invited” her to submit a new OCF-3 to reconsider the termination, Ms. Rumball knew that Traders refused to pay IRB beyond February 25, 2015, and the reasons for this refusal. This refusal to pay IRB triggered the limitation period, which expired on March 4, 2017. [Emphasis added]
[38] This position is disingenuous. Traders’ “decision” is described in the first paragraph of its Letter under the heading Reasons for Decision. The “decision” has two parts. It includes not only a termination of IRBs but also the representation that Ms. Rumball may be eligible for IRBs if she is off work again and submits an updated OCF-3. There is nothing in the Letter which states that IRBs will never be paid beyond February 25, 2015 even if Ms. Rumball is off work again. As such, the first paragraph of the Letter only provides a qualified termination of IRB benefits. The second paragraph of the Letter goes on to describe the steps that Ms. Rumball needs to take if she wishes to dispute the “decision”. Given that the decision found in the first paragraph of the Letter left open the possibility of her future entitlement to IRBs, it is not surprising that Ms. Rumball did not dispute this decision shortly after its release.
[39] The Tribunal’s finding that the Letter was ambiguous was not only a reasonable and “entirely plausible” interpretation (for the reasons set out in para. 25 of the Preliminary Issue Decision) — it was the correct one.
[40] Traders further submits that in coming to the conclusion that the Letter was not a clear and unequivocal denial of IRB, the Tribunal applied a rolling limitation period, rather than a hard limitation period, contrary to established precedent, such as Haldenby v. Dominion of Canada General Insurance Co., 2001 16603 (ON CA), [2001] O.J. No. 3317 (Ont. C.A.). Haldenby holds that a proceeding for accident benefits must be commenced within two years after the insurer’s refusal, regardless of whether the insured qualifies for payment of the benefit at the time of the refusal. In response, Ms. Rumball submits that more recently, in Tomec v. Economical Mutual Insurance Company, 2019 ONCA 882, 148 O.R. (3d) 438, the Ontario Court of Appeal determined that the SABS limitation period is subject to the discoverability principle, meaning that a limitation period is not triggered unless there has been a decision to refuse to pay the accident benefits claimed. Ms. Rumball further submits that this principle also applies to claims for IRBs: See Tagoe v. The Personal Insurance Company, 2023 ONSC 5715.
[41] As noted by the Tribunal, Traders’ submission has no relevance to the analysis of whether the Letter was a “clear and unequivocal” termination of benefits.
ISSUE #3: SHOULD THE RECONSIDERATION DECISION BE SET ASIDE FOR BEING PROCEDURALLY UNFAIR?
[42] In its Request for Reconsideration, Traders acknowledged that its Request was being brought well outside the 21-day timeline for Reconsideration set out in Rule 18.1 of its Common Rules of Practice and Procedure, Licence Appeal Tribunal, Animal Care Review Board, and Fire Safety Commission Common Rules of Practice and Procedure, Version I (October 2, 2017) (the “Rules”) which states:
The Tribunal may, on its own initiative or upon request of a party, if the request is made within 21 days of the date of the decision, reconsider any decision of the Tribunal that finally disposes of an appeal. …
[43] Traders asked that the Tribunal exercise its discretion under s. 7 of the Licence Appeal Tribunal Act, 1999 to grant an extension of time for Reconsideration. Section 7 states:
Despite any limitation of time fixed by or under any Act for the giving of any notice requiring a hearing by the Tribunal or an appeal from a decision or order of the Tribunal under section 11 or any other Act, if the Tribunal is satisfied that there are reasonable grounds for applying for the extension and for granting relief, it may,
(a) extend the time for giving the notice either before or after the expiration of the limitation of time so limited; and
(b) give the directions that it considers proper as a result of extending the time.
[44] The Tribunal dismissed Traders’ request for an extension of time for reconsideration. After reviewing the history of the matter, the Tribunal concluded that s. 7 did not apply to a request to amend the deadline to file a reconsideration request. Instead, if there was any “flexibility”, it was to be found in Rule 3, which allows an adjudicator to liberally interpret or vary a rule in order to ensure a fair, efficient, and timely resolution. The Tribunal saw no reason to apply the flexibility arising from Rule 3 to the matter before it because,
I see no reason to believe that the respondent could not have filed a reconsideration to the Tribunal and an appeal to the Divisional Court in order to respect the timelines of both processes. The respondent chose to pursue the appeal through Divisional Court and was unsuccessful. To allow the respondent to now advance its reconsideration would add further delay to the proceeding for the applicant, who has already been made to wait for and respond to the respondent’s appeal.
[45] Traders mischaracterizes the grounds for challenging the Reconsideration Decision as being related to procedural fairness. None of the grounds it advances suggest a flaw in the procedure used by the Tribunal in arriving at its decision to deny an extension of time. Instead, its challenge is primarily directed at the merits of this decision. The Tribunal’s decision to deny an extension of time was an exercise of its discretion. There was nothing procedurally unfair about the Reconsideration Decision, nor was it unreasonable.
CONCLUSION
[46] Traders has not established that the February 5, 2018 Preliminary Issue Decision or the May 8, 2019 Reconsideration Decision is unreasonable. For the above reasons, Traders’ application for judicial review is dismissed.
[47] As agreed by the parties, Ms. Rumball, as the successful party, is entitled to her costs fixed in the amount of $8,000.00.
Faieta J.
I agree:___________________________
Backhouse J.
I agree:___________________________
Ryan Bell J.
Released: February 14, 2025
Traders General Insurance Company v. Rumball, 2025 ONSC 779
DIVISIONAL COURT FILE NO.: 301/24 DATE: 20250214
ONTARIO
SUPERIOR COURT OF JUSTICE
DIVISIONAL COURT
BACKHOUSE, FAIETA, RYAN BELL JJ.
BETWEEN:
TRADERS GENERAL INSURANCE COMPANY
Applicant
– and –
SHELLEY RUMBALL and LICENCE APPEAL TRIBUNAL
Respondents
REASONS FOR DECISION
FAIETA J.
Released: February 14, 2025

