What is the definition of the executor de son tort and conduct which has given rise to liability?

Counsel have advanced a number of authorities pertaining to the definition of the executor de son tort and conduct which has given rise to liability. It has not been argued before me that this status would not be a valid exception to the principle in Nova v. Grove. In that case, Stevenson J.A. referred to the executor de son tort in obiter, leaving the availability of such an exception an open question. I find that the executor de son tort is an exception to the general rule, as enunciated in Nova v. Grove, that foreign representatives who have not obtained a grant of probate nor letter of administration in Alberta may not be sued in this province.