Can a party to a personal injury action be regarded as a "voluntary" party to the action?

Ontario, Canada


The following excerpt is from Burr v. Tecumseh, 2022 ONSC 412 (CanLII):

In Wolfe v. Pickar, 2011 ONCA 347, 332 D.L.R. (4th) 157, Justice Goudge said, at para. 44: [W]hen a party to an action appears in court and goes beyond challenging the jurisdiction of the court based on jurisdiction simpliciter and forum non conveniens, the party will be regarded as appearing voluntarily, thus giving the court consent-based jurisdiction.

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