Is there any difference between the words "in any manner arising" and "whatsoever arising" in a motor vehicle accident claim?
Ontario, Canada
The following excerpt is from Jensen v Fit City Health Centre Inc., 2015 ONSC 6326 (CanLII):
Nor is it necessary that the words “howsoever” and “whatsoever” arising be used, provided there are equivalent words or phrases to indicate that all claims, including claims of negligence, are covered. In Rauhanen v. Lee, 2003 ABQB 84 (CanLII), 2003 CarswellAlta 103, at para. 25, the court concluded that the words “in any manner arising” in that case were tantamount to the words “howsoever arising” as used in Clarke.
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