Morguard Investments Ltd. v. De Savoyeとは 意味・読み方・使い方

Morguard Investments Ltd. v. De Savoye, [1990] 3 S.C.R. 1077 is the leading decision of the Supreme Court of Canada on the enforcement of extraprovincial judgments. The Court held that the standard for enforcing a default judgment from a different province is not the same as if it were from another country; rather the Court adopts the test from Indyka v. Indyka, [1969] 1 A.C. 33 (H.L.) and the Moran v. Pyle National (Canada) Ltd., [1975] 1 S.C.R. 393 where there must be a "real and substantial connection" between the petitioner and the country or territory exercising jurisdiction.