The respondent wife in a family law proceeding brought a motion seeking an order that service of her Answer and Amended Answer on the applicant husband be deemed service on 36 added corporate and trust respondents, arguing the husband was their alter ego.
The court found insufficient evidence on the motion to make an alter ego finding.
The court validated service on one Ontario corporation and two entities in non-contracting states under the Rules of Civil Procedure as they had actual notice.
However, the court held it had no discretion to validate service on the remaining entities located in Hague Convention contracting states, as Rule 17.05(3) is mandatory and a complete code for service abroad.
