Parul Ahluwalia

The appellant, Paul Blanchard, appealed a trial judgment that found his personal guarantee to JPM Trade Capital Inc. was a continuing guarantee, covering multiple subsequent loans to TEC International Corporation.

The Court of Appeal applied the principles of contractual interpretation from *Sattva* and *Earthco*, affirming that such interpretation is a question of mixed fact and law, subject to palpable and overriding error review.

The court found no palpable and overriding error in the trial judge's determination that the guarantee was continuing, based on the contract's language and surrounding circumstances, and dismissed the appeal.

The Applicant Father sought to reinstate week-about parenting time as per a separation agreement, while the Respondent Mother cross-moved for the appointment of the Office of the Children's Lawyer (OCL), counselling for the eldest child, and supervised parenting.

The court ordered OCL involvement and established a modified parenting schedule for the Father (alternate weekends and Wednesday overnights), noting the detrimental impact of restrictive bail terms on parenting arrangements.

The court also encouraged the parties to discuss mutually agreeable counselling.

The applicants brought a motion seeking a declaration of contempt against Vijai Ramkisson for his repeated failure to attend an examination in aid of execution, as compelled by a prior court order.

Ramkisson argued he lacked knowledge of the order until recently and intended to move to set aside the default judgment.

The court found Ramkisson in contempt, concluding that the order was clear, he had actual knowledge (at least from January 24, 2024, and likely earlier), and he intentionally failed to comply.

The court rejected his explanations as incredible and emphasized that an intention to set aside an order does not excuse non-compliance.

The penalty phase was bifurcated and deferred to allow Ramkisson an opportunity to purge his contempt by attending the examination.