In Kozack v. Richter 1973 CanLII 166 (SCC), [1974] SCR 832 the S.C.C. used the wanton and reckless conduct of the bankrupt as a gauge of his eligibility for a discharge. Although the court found the bankrupt was “a wage earner with a large family in modest circumstances” he was required to pay 50% of his total debts “as a condition of his discharge”.
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