In Dugal v. Manulife, I considered whether the court has jurisdiction to extend the s. 183.14 limitation period in the context of an action under s. 130 of the Securities Act for misrepresentation in the primary market. I concluded, at para. 90, that it would probably not make sense to extend the special circumstances doctrine beyond the existing statutory or common law exceptions that had been engrafted onto specific statutory limitation periods. It was not necessary to decide the issue, however, because I concluded that, even if the jurisdiction existed, I would not have exercised it.
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